The fintech industry is one of the most targeted sectors by cybercriminals. With organizations processing millions of financial transactions daily, regulators and customers expect strong information security controls.
Many fintech companies pursue ISO/IEC 27001 certification to demonstrate that they manage information security risks effectively. However, during certification or surveillance audits, organizations often receive non-conformities that delay certification or require corrective actions.
The good news is that most audit findings are preventable.
In this article, we’ll explore the five most common ISO 27001 non-conformities found in fintech organizations and explain how to address them before your next audit.
What Is an ISO 27001 Non-Conformity?
A non-conformity is a situation where an organization fails to meet one or more requirements of the ISO/IEC 27001 standard or does not follow its own documented Information Security Management System (ISMS).
Auditors typically classify findings as:
Major Non-Conformity
A significant failure that affects the effectiveness of the ISMS or indicates that required processes are missing or not implemented.
Minor Non-Conformity
A smaller issue that does not seriously affect the ISMS but still requires correction.
Organizations are expected to investigate the cause, implement corrective actions, and verify that the issue has been resolved.
1. Incomplete or Outdated Risk Assessments
The Problem
Many fintech companies perform an initial risk assessment during ISO 27001 implementation but fail to update it as the business changes.
Examples include:
- New cloud services
- Mobile applications
- APIs
- Third-party integrations
- Regulatory changes
Without regular reviews, new risks may not be identified or treated appropriately.
Auditor Finding
“The organization’s information security risk assessment has not been reviewed following significant business changes.”
How to Fix It
- Review risk assessments at least annually and after major changes.
- Include cloud, API, and third-party risks.
- Document risk owners and treatment decisions.
- Track progress through a formal risk register.
2. Weak Access Control Management
The Problem
Access control issues remain one of the most common audit findings.
Typical examples include:
- Shared administrator accounts
- Excessive user privileges
- Dormant accounts
- Delayed removal of terminated employees
- Lack of periodic access reviews
Poor access management increases the risk of unauthorized access and insider threats.
Auditor Finding
“User access rights are not reviewed periodically.”
How to Fix It
- Apply the principle of least privilege.
- Review user access regularly.
- Remove inactive accounts promptly.
- Require Multi-Factor Authentication (MFA) for privileged accounts.
- Maintain approval records for access changes.
3. Poor Documentation and Evidence
The Problem
One of the biggest reasons organizations struggle during audits is the absence of evidence.
Many security controls exist but cannot be demonstrated because documentation is incomplete or inconsistent.
Common missing evidence includes:
- Security awareness training records
- Vulnerability scan reports
- Internal audit reports
- Incident response exercises
- Management review meeting minutes
- Asset inventories
Auditor Finding
“The organization could not provide objective evidence demonstrating implementation of required controls.”
How to Fix It
Create and maintain an evidence repository that includes:
- Security policies
- Procedures
- Logs
- Audit reports
- Training records
- Risk assessments
- Meeting minutes
- Corrective action records
Remember:
If it isn’t documented, auditors may conclude it didn’t happen.
4. Weak Third-Party Risk Management
The Problem
Fintech companies rely heavily on:
- Cloud providers
- Payment processors
- Software vendors
- Managed Service Providers (MSPs)
- API partners
However, many organizations fail to assess vendor security before onboarding or monitor vendor risks throughout the relationship.
Auditor Finding
“Third-party security assessments have not been completed for critical service providers.”
How to Fix It
Implement a structured Third-Party Risk Management (TPRM) program by:
- Maintaining a vendor inventory.
- Classifying vendors by risk.
- Conducting security assessments before onboarding.
- Reviewing contracts for security clauses.
- Monitoring vendor performance and compliance regularly.
5. Ineffective Incident Response Testing
The Problem
Many organizations have documented incident response plans but rarely test them.
Without regular exercises, teams may not know how to respond effectively during a real cyber incident.
Auditor Finding
“Incident response procedures have not been tested.”
How to Fix It
Conduct regular:
- Tabletop exercises
- Phishing simulations
- Ransomware response drills
- Business continuity tests
- Disaster recovery exercises
Document:
- Lessons learned
- Improvement actions
- Updated procedures
Testing demonstrates that the organization is prepared to respond effectively to security incidents.
Bonus: Other Common ISO 27001 Findings
Auditors also frequently identify:
- Missing asset inventories
- Weak password policies
- Incomplete vulnerability management
- Poor patch management
- Missing security awareness training
- Lack of internal audits
- Incomplete Statement of Applicability (SoA)
- Missing business continuity testing
- Insufficient log monitoring
- Weak backup testing
Addressing these areas proactively can improve audit readiness.
How to Prepare for an ISO 27001 Audit
Before your audit:
- Review your ISMS documentation.
- Verify that all required policies are current.
- Ensure risk assessments are up to date.
- Complete internal audits.
- Conduct management reviews.
- Verify corrective actions have been implemented.
- Gather evidence for each applicable control.
- Confirm employees understand their security responsibilities.
Preparation reduces surprises during the audit.
Best Practices for Fintech Organizations
To maintain ISO 27001 compliance:
- Perform regular risk assessments.
- Conduct vulnerability scans and penetration tests.
- Monitor third-party risks.
- Enforce strong access controls.
- Review logs and security alerts.
- Train employees regularly.
- Maintain comprehensive documentation.
- Test incident response and business continuity plans.
- Track corrective actions to completion.
A culture of continuous improvement is key to long-term success.
Final Thoughts
Achieving ISO/IEC 27001 certification is only the beginning. Maintaining an effective Information Security Management System requires ongoing attention to risk management, documentation, access control, vendor oversight, and incident preparedness.
By understanding the most common non-conformities and addressing them proactively, fintech organizations can improve security, streamline audits, and build greater trust with customers, regulators, and business partners.
Frequently Asked Questions (FAQ)
What is a non-conformity in ISO 27001?
A non-conformity is a failure to meet a requirement of ISO/IEC 27001 or to follow the organization’s own documented ISMS processes.
What is the difference between a major and minor non-conformity?
A major non-conformity indicates a significant breakdown in the ISMS or a missing required process. A minor non-conformity is a less serious issue that still requires corrective action but does not fundamentally compromise the effectiveness of the ISMS.
Why do fintech companies commonly receive audit findings?
Rapid growth, cloud adoption, complex third-party relationships, and evolving regulatory requirements can make it challenging to keep documentation, risk assessments, and security controls up to date.
How can organizations reduce ISO 27001 non-conformities?
Regular internal audits, up-to-date risk assessments, comprehensive documentation, strong access management, vendor risk reviews, and routine testing of incident response and business continuity plans can significantly reduce audit findings.
ABOUT THE AUTHOR
Jackson Godwin is a Cybersecurity Analyst and Penetration Tester at Jackson Technology, a cybersecurity and data protection consulting firm based in Abuja, Nigeria, serving enterprise clients across banking, fintech, oil and gas, and the public sector. His expertise spans vulnerability assessment and penetration testing (VAPT), cloud security, and compliance advisory covering ISO 27001, the NDPA 2023, and GDPR. He is also affiliated with TechTrain Academy, where he supports cybersecurity education for African professionals.
info@jacksontechnology.com.ng | jacksontechnology.com.ng