The ISO 27001 is emerging as a major obligation in the UAE among businesses dealing with customer information, having enterprise customers, or seeking to be eligible as a vendor to be included in the tender and vendor boarding. It’s no longer just “an IT thing.” It is a business confidence indicator, and a lot of UAE customers are now looking to have formal information protection measures.
However, the majority of ISO 27001 audit problems do not occur due to the fact that a company does not care about security. They occur due to the fact that the system is available in documents whereas evidence is lacking during the audit. Policies are okay, and the organization cannot demonstrate the uniformity of implementation.
The Audit Reality in UAE (What Auditors Focus On)
During the UAE ISO 27001 audits, the auditors tend to concentrate on four areas, which are:
ISMS Scope (what is included, what is excluded, and why)
Risk Assessment + Risk Treatment (the way risks were identified, rated and treated)
Statement of Applicability (SoA) (which Annex A controls apply and implementation status)
Records, logs, approvals, reviews, and corrective actions are all evidence. Unless your team can demonstrate the evidence of these areas, the audit is going to be easy and predictable.
If your team can show clear evidence for these areas, the audit becomes smooth and predictable. If your organization wants to reduce audit findings and build a practical ISMS with real evidence, getting ISO 27001 certification support in UAE can make the implementation and audit preparation much smoother.
10 Common ISO 27001 Gaps in UAE Audits
1) Scope Is Unclear or Unrealistic
What auditors see:
Scope statements like “all departments and all activities” with no boundaries, locations, or system clarity.
Why it happens:
Companies try to look broad and strong, but end up creating a scope they can’t control or prove.
How to fix it (practical steps):
Define scope by services, locations, and systems
Mention what’s included (example: cloud email, CRM, ERP, laptops)
Document exclusions with valid reasoning
2) Risk Assessment Is Generic (Not Based on Real Assets)
What auditors see:
Copy-paste risks like “hacking” or “data breach” without linking them to actual systems, users, or processes.
Why it happens:
Teams use templates without mapping risks to business reality.
How to fix it (practical steps):
Identify risks per asset and process (email, file storage, finance approvals, HR records)
Assign risk owners
Define likelihood and impact criteria
Review and update risk assessment at least annually (or after major change)
3) Statement of Applicability (SoA) Doesn’t Match Implementation
What auditors see:
Controls marked “applicable” in the SoA, but no proof that they’re implemented.
Why it happens:
SoA is treated as a formality instead of a live document.
How to fix it (practical steps):
Update SoA after every risk review
Add short implementation notes for each control
Cross-check each “applicable” control with real evidence (logs, reports, records)
4) Access Control Is Weak (No Approvals or Reviews)
What auditors see:
Users have access, but there’s no record showing who approved it and why.
Why it happens:
Access is handled informally through messages or verbal requests.
How to fix it (practical steps):
Maintain a user access request and approval method (ticket, form, email)
Run quarterly access reviews for key systems
Remove access immediately when staff leave (joiner-mover-leaver process)
5) Shared Accounts Still Exist
What auditors see:
Multiple staff using one login for tools, admin panels, or shared emails.
Why it happens:
It feels faster, and teams avoid managing individual accounts.
How to fix it (practical steps):
Assign unique accounts to each user
Use role-based access control (RBAC)
If shared access is unavoidable, document the reason and add extra monitoring
6) Supplier Security Is Not Controlled
What auditors see:
Vendors handle data or systems, but there’s no supplier risk assessment or security requirement.
Why it happens:
Procurement focuses on cost and delivery, not security.
How to fix it (practical steps):
Classify suppliers as critical or non-critical
Add security clauses in contracts (confidentiality, access control, incident reporting)
Perform supplier evaluation and annual review for critical vendors
7) Incident Management Exists Only in Policy
What auditors see:
An incident response procedure exists, but there’s no incident log, no testing, and staff don’t know how to report issues.
Why it happens:
Companies assume “no incidents happened,” so nothing needs recording.
How to fix it (practical steps):
Maintain an incident register (even for minor events)
Define reporting channels and escalation
Run a tabletop exercise twice a year
Record corrective actions and lessons learned
8) Internal Audit Is Weak or Too Basic
What auditors see:
Internal audits are done using generic checklists, with no testing of controls or evidence.
Why it happens:
Internal audit is treated as a checkbox activity.
How to fix it (practical steps):
Audit both ISO clauses + Annex A controls
Record findings with clear evidence
Track corrective actions to closure
Audit high-risk areas first (access control, backups, suppliers, incidents)
9) Management Review Is Missing Key Inputs
What auditors see:
Management review minutes exist, but they lack decisions, KPIs, or improvement actions.
Why it happens:
Reviews are done quickly, without measurable inputs.
How to fix it (practical steps):
Include ISMS KPIs (incidents, patching, training completion, access review results)
Record management decisions and assigned actions
Track follow-ups in the next review
10) Backup and Recovery Evidence Is Not Available
What auditors see:
Backups exist, but no restore test evidence is available.
Why it happens:
Teams assume backup tools are enough without verification.
How to fix it (practical steps):
Test restore monthly or quarterly
Keep restore test reports/screenshots
Define RTO/RPO based on business needs
Align backups with business continuity planning
Conclusion
ISO 27001 audits in the UAE are mostly about proof. Policies matter, but evidence matters more. If your scope is clear, risks are real, and controls are implemented with records, your audit becomes a validation step, not a surprise inspection.
