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Internal and External Auditors

Overview​

Auditors validate the effective application of the practices described in the SbD-ToE.
They verify risk classifications, traceability, evidence of application, and alignment with regulatory requirements across all chapters.

Key Responsibilities​

  • Validate the effective application of the prescribed practices
  • Assess risk classifications, requirements, traceability and evidence
  • Produce independent reports and improvement recommendations
  • Do not audit processes, controls or decisions they took part in: the auditor and the audited function are different people
  • Attest compliance before the authorities

Organisational Context​

They are essential instruments for demonstrating compliance to supervisory authorities, as required by NIS2, DORA, GDPR and ISO 27001.

Regulatory Framework​

They are formal instruments for demonstrating compliance to the authorities:

  • NIS2: Security and compliance audits
  • DORA: Resilience testing and third-party audits
  • GDPR: Data protection audits
  • ISO 27001/27002: ISMS audits

Activities by Chapter​

Cross-cutting - All Chapters​

Validate evidence of practice application, verify traceability of decisions (ADR, exceptions, risk acceptances), confirm alignment with regulatory requirements (NIS2, DORA, GDPR, SSDF, ISO 27001).

Associated requirements:

Ch. 01 - Application Classification​

Verify risk classifications and their adequacy to the technical and business context. Validate governance KPIs.

Associated requirements:

Ch. 02 - Security Requirements​

Validate the implementation of requirements per level (L1/L2/L3), verify traceability requirements → controls → evidence.

Ch. 07 - Secure CI/CD​

Validate commit → pipeline → release traceability, verify exception management.

Associated requirements:

Ch. 08 - IaC and Infrastructure​

Validate file → resource → environment traceability, verify change windows and approvals, validate formal exceptions.

Associated requirements:

Ch. 14 - Governance and Contracting​

Audit exception documentation, verify formal approvals, validate contractual compliance with suppliers, verify complete traceability.

Associated requirements:


Chapter References​

Auditors use every chapter as a source of evidence: