For any organization that owns or operates part of the Bulk Electric System, a NERC CIP audit is never just a paperwork exercise. It is a structured examination of whether the controls protecting generation, transmission, and grid-supporting cyber assets actually work the way they are documented to work. Utilities and generation operators spend months preparing evidence binders, updating procedures, and reviewing access logs, yet audit findings still happen with striking regularity across the industry.

Before we begin, don’t forget to check out our previous post on “McKesson data breach investigation: ShinyHunters, SaaS identity risk and data extortion” here.

What makes this pattern interesting is that most findings are not caused by a lack of effort. They are caused by gaps that quietly grow between what a program says it does and what it actually does on the plant floor, in the control room, or inside a substation network. An asset inventory that was accurate eighteen months ago. A firewall rule that was approved but never re-reviewed. A recovery plan that has never been tested against a real outage scenario. Individually, these look like small administrative lapses. Collectively, they represent the erosion of an OT security program's operational integrity.

This Blog walks through fifteen of the most common NERC CIP audit findings that Regional Entities continue to identify, why each one keeps recurring even among mature programs, and the practical steps that OT security leaders, compliance managers, and plant operations teams can take to close these gaps before the next audit cycle begins.

Why NERC CIP Audit Findings Deserve Board-Level Attention

It is tempting to treat CIP compliance as a specialized function that lives entirely within the security or compliance department. That framing undersells what audit findings actually represent. Every finding tied to Critical Cyber Asset identification, access management, or incident response reflects a control that could fail during a real security event, not just during a review.

Consider what happened during the well-documented 2015 and 2016 attacks on Ukrainian power distribution companies. Investigators later determined that attackers had been inside the network for months, using legitimate remote access credentials and reconnaissance techniques that a properly enforced access review and network segmentation program would likely have surfaced. The attack itself lasted only a few hours, but the conditions that allowed it to succeed were the same categories of weaknesses regulators look for during CIP audits: undocumented remote access paths, insufficient monitoring of operational technology traffic, and unclear ownership of which assets actually mattered most to grid reliability.

This is why audit findings should never be viewed purely as a compliance scorecard. They are a proxy for operational resilience. A utility with a clean CIP audit record is, more often than not, a utility that has genuinely mapped its critical assets, hardened its access controls, and rehearsed its response to disruption. A utility with recurring findings has usually left gaps that an adversary, an insider, or even a routine equipment failure could exploit.

Boards, executives, and plant leadership increasingly understand this connection. Insurance underwriters ask about audit history when pricing cyber liability coverage. Regional Entities have signaled that repeat findings on the same standard draw significantly more scrutiny than a first-time issue. And perhaps most importantly, every finding represents time, budget, and internal credibility that gets diverted toward remediation instead of forward-looking security improvements.

Understanding the NERC CIP Audit Landscape

Before addressing the specific gaps, it helps to understand where audit findings tend to concentrate. NERC CIP standards span identification, protection, monitoring, and recovery, and different standards produce different types of findings depending on how mature an organization's OT security program is.

Auditors typically look for two things at once: whether a documented process exists, and whether evidence proves that process was followed consistently across the audit period. Findings usually emerge in the gap between those two things, not because either element is missing entirely, but because they have drifted apart over time.

The 15 Most Common NERC CIP Audit Gaps

1. Incomplete or Outdated Asset Inventories

Asset inventories are the foundation of nearly every CIP standard, yet they are one of the most frequently cited gaps. Plant environments change constantly: a replacement PLC gets installed during an outage window, a temporary engineering laptop gets connected for commissioning, or a vendor swaps a network switch during maintenance. If the inventory is not updated in near real time, everything built on top of it, including categorization, access control, and monitoring scope, becomes inaccurate by extension.

The fix: Move away from manual spreadsheet-based inventories toward a continuously updated asset discovery process that reconciles automatically with change management records. Passive network monitoring tools designed for OT environments can identify new devices without disrupting industrial processes, giving compliance teams a living inventory rather than a point-in-time snapshot.

2. Inaccurate BES Cyber Asset Categorization

Categorization under CIP-002 determines nearly everything downstream, including which controls apply and how rigorously they must be enforced. Auditors frequently find that categorization decisions were made once, during initial compliance efforts, and never revisited as facilities were upgraded, expanded, or reconfigured.

The fix: Build categorization review into your annual change management cycle rather than treating it as a standalone compliance task. Any capital project or major system upgrade should trigger a categorization reassessment as a standard checklist item, not an afterthought discovered during audit preparation.

3. Missing or Insufficient Evidence

Perhaps the most common finding type across all standards is not that a control failed, but that the organization could not produce sufficient evidence proving the control operated consistently. A quarterly access review that happened but was never documented is, from an audit perspective, indistinguishable from a review that never happened at all.

The fix: Treat evidence generation as part of the control itself, not a separate administrative step performed afterward. Automated evidence capture, where system logs, ticketing records, and approval workflows generate their own audit trail, removes the dependency on someone remembering to document proof after the fact.

4. Weak or Inconsistent Access Controls

Access management findings frequently involve accounts that were never deprovisioned after a role change, shared credentials used for operational convenience, or access grants that were never re-authorized on schedule. In OT environments, where uptime pressure often discourages disruptive account changes, these gaps can persist for years.

The fix: Implement role-based access reviews tied directly to HR and contractor lifecycle events, not just calendar-based quarterly checks. Pair this with least-privilege principles for engineering workstations and HMIs, ensuring that access is granted based on operational necessity rather than convenience.

5. Undocumented Network Paths and Connections

Electronic Security Perimeter findings often surface when auditors discover a network connection, sometimes a vendor remote access tunnel, a wireless bridge, or a dual-homed engineering laptop, that was never formally documented or approved. These paths frequently exist for legitimate operational reasons but were never captured in the network diagrams used for compliance evidence.

The fix: Conduct periodic network path validation using passive traffic analysis rather than relying solely on documentation review. If a device is communicating across a segment boundary that is not reflected in your architecture diagrams, that discrepancy needs to be resolved immediately, either by updating documentation or removing the unauthorized path.

6. Outdated or Drifted System Configurations

Configuration baselines established during commissioning rarely stay accurate. Firmware updates, emergency patches applied during outages, and vendor-performed maintenance can all introduce configuration drift that goes unrecorded. Auditors comparing current configurations against baseline documentation frequently find discrepancies that were never formally change-managed.

The fix: Establish automated configuration monitoring that flags deviations from approved baselines in near real time. Where automation is not feasible for legacy OT devices, build configuration verification into every maintenance window as a mandatory checklist step rather than an optional best practice.

7. Gaps in Patch Management Documentation

CIP-007 requires a documented process for evaluating security patches, but many organizations struggle to consistently prove that every applicable patch was evaluated, and if not applied, that a compensating measure was implemented and documented. Vendor-specific patch cadences, testing requirements, and outage scheduling constraints make this one of the more operationally difficult standards to satisfy consistently.

The fix: Build a formal patch evaluation cycle with defined timelines for assessment, testing, and either deployment or documented mitigation. Maintain a single source of truth that ties each patch decision to a specific asset, evaluation date, and rationale, so evidence can be produced instantly rather than reconstructed under audit pressure.

8. Insufficient Security Event Monitoring

Many OT environments still rely on limited logging scope or manual log review processes that cannot realistically detect anomalous behavior across dozens or hundreds of assets. Auditors increasingly test not just whether logging exists, but whether the organization can demonstrate meaningful detection capability.

The fix: Deploy OT-aware monitoring that understands industrial protocols and can distinguish between normal process variation and genuinely anomalous behavior. Logging alone is not sufficient; the ability to correlate, alert, and respond is what auditors, and real incidents, actually require.

9. Untested Incident Response Plans

A written incident response plan that has never been exercised against a realistic OT-specific scenario often looks fine on paper but fails the moment it needs to work. Auditors frequently find that tabletop exercises were generic, IT-focused, or did not involve the operational personnel who would actually be on the front line during a real event.

The fix: Run OT-specific tabletop exercises that involve control room operators, engineering staff, and plant leadership, not just the security team. Scenarios should reflect realistic conditions, such as a ransomware event affecting engineering workstations during a planned outage, so that gaps in coordination surface during a drill rather than during an actual incident.

10. Incomplete Recovery Plan Documentation

CIP-009 recovery plans are frequently written to satisfy the letter of the standard but lack the operational detail needed to actually restore systems under pressure. Findings often cite recovery plans that were never validated through an actual restoration test, meaning the organization cannot demonstrate the plan would work as written.

The fix: Schedule annual recovery exercises that go beyond tabletop discussion and actually test backup restoration, system rebuild timelines, and communication protocols. Document lessons learned from each exercise and feed them back into plan updates, creating a continuous improvement cycle rather than a static document.

11. Supply Chain Risk Management Shortfalls

Since CIP-013 came into effect, supply chain risk management has become one of the more challenging standards to operationalize consistently. Findings often involve vendor risk assessments that were completed inconsistently, procurement processes that did not consistently incorporate cybersecurity risk criteria, or a lack of ongoing monitoring for vendor-related risk after initial onboarding.

The fix: Integrate cybersecurity risk evaluation directly into procurement workflows so that it happens automatically rather than as a parallel process that can be skipped under deadline pressure. Maintain ongoing vendor risk monitoring rather than treating supplier assessment as a one-time gate at contract signing.

12. Inconsistent Handling of BES Cyber System Information

CIP-011 findings frequently involve sensitive information, such as network diagrams, asset lists, or configuration details, being stored, shared, or disposed of inconsistently with the organization's own information protection policy. This often happens when engineering teams share technical documentation through channels that were never designed for sensitive data handling.

The fix: Classify and label BES Cyber System Information clearly at the point of creation, and restrict sharing channels to approved, monitored platforms. Regularly audit where sensitive documentation actually lives, not just where policy says it should live.

13. Delayed or Incomplete Personnel Risk Assessments

CIP-004 findings often involve personnel risk assessments or training records that were completed late, incompletely documented, or not properly tracked for contractors and temporary staff who require the same rigor as full-time employees.

The fix: Build personnel risk assessment and training tracking into a centralized system that flags upcoming deadlines automatically, rather than relying on manual tracking spreadsheets that are easy to overlook during busy operational periods.

14. Weak Physical Security Controls at Perimeter Boundaries

While often overshadowed by cyber-specific findings, physical security gaps at Physical Security Perimeters remain common, including unmonitored access points, inconsistent visitor logging, or physical access authorization records that do not match actual badge access logs.

The fix: Reconcile physical access control system records against authorization documentation on a regular schedule, not just before an audit. Physical and cyber access reviews should be aligned on the same cadence so discrepancies surface quickly.

15. Governance Gaps Between Policy and Operational Reality

The final and perhaps most fundamental gap is a disconnect between what corporate policy documents describe and what actually happens in day-to-day plant operations. This often happens when policies are written by compliance or corporate security teams without sufficient input from the operational personnel who must actually execute them.

The fix: Involve plant operations, control room staff, and engineering leadership directly in policy development, not just policy review. A policy that reflects operational reality is far more likely to be followed consistently, which is ultimately what auditors are testing for.

Practical Recommendations for Reducing Audit Findings

Closing individual gaps is important, but sustainable compliance requires a shift in how organizations approach the entire program. The following practices help move CIP compliance from a reactive, audit-cycle activity toward a continuous operational discipline.

• Build compliance into daily operations, not just audit preparation. Programs that treat compliance as something to prepare for once a year consistently produce more findings than programs that embed evidence generation into routine workflows.

• Prioritize remediation based on operational risk, not just audit severity. A gap affecting a high-impact control center deserves faster attention than a minor documentation lapse at a low-impact facility, even if both technically constitute findings.

• Conduct internal reviews using the same rigor as an actual audit. Mock audits performed by an independent internal team, or an outside partner, frequently surface the same gaps a Regional Entity auditor would find, but with time to fix them before they become formal findings.

• Ask better questions during internal reviews. Instead of asking whether a policy exists, ask whether you can produce evidence a control operated consistently for the last twelve months, for every applicable asset. This reframing exposes evidence gaps long before an actual audit does.

• Distinguish documentation problems from control failures. A missing signature on an evidence form is a different category of risk than an access control that genuinely failed to restrict unauthorized access. Both need fixing, but they require different urgency and different remediation approaches.

• Automate evidence collection wherever technically feasible. Manual evidence gathering is not just inefficient, it is a leading cause of the inconsistency that produces findings in the first place.

• Maintain living documentation. Network diagrams, asset inventories, and configuration baselines should be treated as continuously updated operational tools, not static compliance artifacts revisited only during audit preparation season.

Real-World Impact: Why This Matters Beyond Compliance

The 2021 Colonial Pipeline incident is frequently cited in cybersecurity discussions, and for good reason: it illustrated how a single compromised credential, absent multifactor authentication, could disrupt a critical fuel supply chain across an entire region. While that particular incident involved IT systems rather than a NERC CIP-regulated environment, the underlying lesson translates directly. Access control gaps, the same category of gap that frequently generates CIP-004 and CIP-005 findings, are rarely theoretical. They represent real pathways that real incidents have exploited.

Similarly, incidents involving unpatched industrial control systems have repeatedly demonstrated that patch management gaps are not merely a documentation inconvenience. When a known vulnerability remains unaddressed on an internet-facing or improperly segmented OT asset, the gap between compliance finding and operational compromise can be measured in weeks rather than years.

This is the core argument for taking audit findings seriously well beyond the immediate goal of avoiding penalties. Every one of the fifteen gaps described above maps to a category of risk that has caused real operational disruption somewhere in the industry. Treating compliance remediation as synonymous with security hardening is not just good regulatory practice, it is good risk management.

How Shieldworkz Supports Organizations

Shieldworkz works alongside utilities, generation operators, and critical infrastructure teams to close the gap between documented compliance and demonstrable operational security. Our approach is built around the reality that OT environments cannot be secured using IT playbooks alone, and that compliance evidence should be a byproduct of good security practice, not a separate burden layered on top of it.

• Continuous OT asset visibility that keeps inventories accurate without requiring manual updates, giving compliance and security teams a shared, real-time source of truth.

• Passive network monitoring built for industrial protocols, identifying undocumented paths, unauthorized devices, and configuration drift without disrupting production.

• Access governance support that aligns account lifecycle management with HR and contractor processes, closing the gap between policy and actual account activity.

• Evidence-ready reporting that maps directly to CIP standard requirements, reducing the manual effort required during audit preparation.

• Incident response and recovery exercise facilitation including OT-specific tabletop scenarios designed around your actual plant environment rather than generic IT templates.

• Supply chain risk assessment support helping procurement and engineering teams evaluate vendor risk consistently and maintain ongoing visibility after onboarding.

• Independent readiness assessments performed with the same rigor as a formal audit, surfacing gaps early enough to remediate them on your own timeline.

Our goal is not simply to help organizations pass their next audit. It is to help build OT security programs resilient enough that a clean audit becomes a natural outcome of strong daily practice.

Conclusion

NERC CIP audit findings rarely stem from a single dramatic failure. They accumulate quietly, through inventories that fall slightly out of date, access reviews that get postponed during a busy quarter, or recovery plans that were written once and never tested. Each gap on its own can seem minor. Together, they represent the difference between a compliance program that looks good on paper and one that genuinely protects the reliability of the grid.

The organizations that consistently avoid repeat findings are the ones that stop treating compliance as a periodic event and start treating it as a continuous operational discipline, one where evidence generation, asset visibility, and access governance happen automatically as part of daily work rather than as a scramble before the next assessment window.

If your organization is preparing for an upcoming audit, recovering from recent findings, or simply looking to strengthen the operational integrity behind your CIP compliance program, the earlier these gaps are identified, the more manageable they are to fix.

Book a Free Consultation with Our Experts

Our OT security specialists can help you assess where your compliance program stands today, identify the gaps most likely to surface in your next audit, and build a practical remediation roadmap tailored to your operational environment. Reach out to schedule a free, no-obligation consultation and take a proactive step toward a stronger, audit-ready security posture.

Additional resources:

Comprehensive Guide to Network Detection and Response NDR in 2026 here
NERC CIP-015 Internal Network Security Monitoring Readiness Checklist for Electric Utilities here
OT SOC Foundational Guide here
Managed SOC Service here
OT Cyber Threat Intelligence Advisory - Middle East here
NIS2 Directive Achieving NIS2 Compliance Through IEC 62443 here
What Is Removable Media? Risks, Policies, and Industrial OT Security Solutions here
Free Removable Media Policy Template for OT and IT Teams here