Sample report · Anonymised ← Back to home

Deliverable sample · Gap analysis

Gap Analysis Report ISO 27001 · NIS2 · DORA

This is a real deliverable from one of our projects — anonymised. It shows the structure, the depth and the language delivered to the board after two weeks of analysis.

I want one of my own
Client
Anonymised · Manufacturing, Larissa
Size
240 employees · 3 sites
Frameworks
ISO/IEC 27001:2022 · NIS2 · DORA · GDPR
Version
v1.4 · Final
Duration
14 days · 2 weeks
Classification
Confidential · Internal
SAMPLE
01

Executive summary

The Organisation operates a mature technology environment — active EDR, centralised identity management, documented backups. The security management system, however, remains fragmented into informal practices: things done correctly, without documentation that holds up under audit.

The analysis identified 47 findings. Three are critical, nine high, eighteen medium, seventeen low. None of the critical findings relates to technology — all three concern incomplete documentation, governance and accountability. That's good news: they close in weeks, not months, and don't require new tooling investments.

The largest compliance risk is not ISO 27001 — it's NIS2. As an essential entity, the Organisation is exposed to fines of up to €10m or 2% of global annual turnover, and to personal liability of the management body (Article 20). Today there's no documented 24-hour / 72-hour reporting procedure, and no recorded responsibility at board level.

On completing the 12-week roadmap, our assessment is that the Organisation reaches Stage 2 readiness for ISO 27001 with 94% control coverage, and 89% on the NIS2 Article 21 measures.

02

Scope & methodology

What was reviewed, how, and what's not covered by this analysis.

The analysis covered the entire production footprint and core services. 14 interviews were conducted with process owners, and 3 technical verifications in a test environment.

The method followed the logic requirement → control → evidence → owner. Every finding is documented with at least one specific element — a missing policy, an incomplete record, a measurable response gap.

Out of scope: physical security of warehouses outside Larissa, non-EU subsidiaries, and systems under decommissioning. These weren't scored and don't count toward the coverage percentages.

03

Findings overview

47 findings, categorised by severity and framework.

3
Critical Immediate action · 0–2 weeks
9
High Before the audit
18
Medium Within 6 weeks
17
Low Continuous improvement
ISO 27001
94%
NIS2
89%
DORA
94%
GDPR
98%

The three critical findings concern supply chain management, the incident reporting process and the absence of board-level accountability. All three close with procedural changes, not purchases.

04

Detailed findings

Four representative findings — as they appear in the full report.

F-023 Incomplete supplier security assessment Critical

Of the 31 critical suppliers processing or with access to the Organisation's data, 7 have no documented security assessment. There's no supplier register with criticality classification, and no standard security clauses in contracts.

This breaches A.5.19–A.5.22 of ISO 27001:2022 and Article 21.2.d of NIS2, which explicitly requires security measures in the supply chain.

Requirement
A.5.19–A.5.22 · NIS2 Art. 21.2.d
Owner
Procurement / CISO
Estimated closure
3 weeks
F-031 No documented incident reporting process Critical

The average response time for security incidents is 41 hours from detection to escalation. There's no documented escalation flow, and no designated person responsible for reporting to the competent authority.

NIS2 requires early warning within 24 hours and a detailed report within 72 hours. Today the Organisation cannot demonstrate that it meets these deadlines.

Requirement
A.5.24–A.5.28 · NIS2 Art. 23
Owner
SOC Lead / CISO
Estimated closure
2 weeks
F-012 No periodic access rights review High

The Organisation grants access in a controlled way, but hasn't carried out a periodic review in the last 14 months. The last review was ad-hoc, without documentation.

This breaches A.5.18 and A.8.2, and creates immediate audit risk — the auditor will ask for evidence of a review and won't find it.

Requirement
A.5.18 · A.8.2
Owner
IT Operations
Estimated closure
2 weeks
F-041 Business continuity test not documented High

A recovery test was carried out in November 2024, but there's no documentation — no minutes, no RTO/RPO measurements, no corrective actions. The business continuity plan hasn't been approved by management since 2023.

Requirement
A.5.29 · A.5.30
Owner
IT Director
Estimated closure
3 weeks
05

Risk register excerpt

Sorted by residual risk. Excerpt — the full register contains 47 rows.

ID Risk Likelihood Impact Rating Owner Status
R-003 Data breach through unassessed supplier High High Critical CISO Open
R-007 Failure to meet NIS2 24h/72h deadlines High Medium Critical SOC Lead In progress
R-014 Unauthorised access via stale entitlements Medium High High IT Ops Open
R-019 Service outage without documented recovery plan Medium High High IT Director Open
R-022 Software development documentation non-compliance Medium Medium Medium Eng Lead Scheduled
R-031 Loss of documentation on staff turnover Medium Low Medium HR / CISO Scheduled
R-038 Incomplete phishing training for new joiners Low Medium Low HR In progress
06

Control coverage

Coverage by category of Annex A of ISO/IEC 27001:2022 — 93 controls in total.

Category Controls Coverage Gaps Status
A.5 · OrganisationalPolicies, risk, supply chain 37 92% 3 ✓ pass
A.6 · PeopleBackground checks, training 8 100% 0 ✓ pass
A.7 · PhysicalPerimeter, equipment, media 14 93% 1 ✓ pass
A.8 · TechnologicalAccess, encryption, development 34 91% 3 ⚠ review
Total ISO 27001 93 94% 7 ✓ ready

The weakness is in A.8 — specifically in secure software development (A.8.25–A.8.28) and technical vulnerability management (A.8.8). Both are covered with procedural changes.

07

12-week roadmap

Every action has an owner, a deliverable and a completion week. Updated weekly.

Action 010203040506 070809101112
Scoping & discoveryGap register · delivery
SoA & risk planStatement of Applicability
Control implementationCritical + high findings
Internal auditDry run · CAPA
Stage 1 & 2 auditAuditor on site

The roadmap is interdependent: the implementation stage doesn't start until the risk plan is approved by management, and the internal audit doesn't start until the critical findings are closed. This prevents the common pattern of "skipping steps" that leads to failure at Stage 2.

08

Evidence checklist

The artefacts the auditor asks for — with their current status.

✓ Information Security PolicyVersion 2.1 · approved by the board Ready
✓ Information asset inventory247 assets · updated Q3 2025 Ready
✓ Risk assessment 2025Methodology + results Ready
! Statement of Applicability (SoA)93/93 controls · final approval pending In progress
! Supplier register7 critical suppliers without assessment In progress
✕ Incident reporting procedure 24h/72hRequired by NIS2 Article 23 Missing
✕ Management reviewRequired 2×/year · last in 2023 Missing
✕ Internal audit reportNever carried out Missing
✓ Staff training record94% coverage · 12 outstanding Ready
! Business continuity planLast tested 2024 · no documentation In progress
✓ Access grant / revoke logComplete since Q1 2025 Ready
✕ Secure development documentationSDLC · code review · A.8.25–A.8.28 Missing
09

Next steps

What happens after this report is delivered.

The first step is approval of the risk plan by the board. It isn't a formality — it's the foundation on which the entire ISMS stands, and the first thing the auditor asks for.

The second is starting the implementation stage, with priority on the three critical findings. These close with procedural changes, not technology, and can be completed within the first five weeks.

Want an analysis like this for your organisation?

Two weeks. A prioritised gap register, a costed 12-week roadmap, and an executive summary for the board. No commitment, no charge.