Risk Assessment vs Internal Audit - ISO 27001 Compliance
- Kamalika Majumder | DevOps & ISO 27001 Consultant
- Jul 18
- 5 min read
Risk Assessment and Internal Audit - While they may sound similar and even overlap in their objectives, they are distinct processes serving different purposes. Understanding the differences between these two—and whether Risk Assessment can be automated—can help organizations better allocate resources, improve security posture, and meet compliance requirements effectively.
Risk Assessment: Proactive by Design
Risk Assessment is a forward-looking activity. Its main purpose is to identify, analyze, and evaluate risks that could impact the confidentiality, integrity, or availability of an organization’s information assets. It’s an essential step in any risk management process and forms the basis for selecting appropriate controls.
A typical Risk Assessment process includes:
Asset identification: What needs to be protected?
Threat identification: What can go wrong?
Vulnerability assessment: What weaknesses can be exploited?
Impact and likelihood analysis: What’s the potential damage and how likely is it?
Risk evaluation and treatment: What are the priorities and what can be done?
The goal here is to take a proactive stance, minimizing future threats before they can become incidents. Risk Assessments are not one-time efforts—they must be continuous and adaptive as the business, technology, and threat landscape evolve.
Internal Audit: Retrospective and Evidence-Driven
In contrast, an Internal Audit is a retrospective, compliance-focused activity. The objective is to review and verify whether an organization’s controls, policies, and procedures are being followed as intended.
It ensures that the risk treatments and controls designed during Risk Assessment are actually working in practice.
Key characteristics of Internal Audits:
Focus on conformance and effectiveness.
Evaluate documentation, evidence, and process adherence.
Identify gaps, non-conformities, and areas for improvement.
In ISO 27001, internal audits are mandatory to verify that the ISMS is functioning as intended.
Internal Audits can also surface new risks, but their job is not to manage or prioritize those risks—it’s to check whether the risk management process and all related controls are being implemented correctly.
Which Comes First in ISO 27001:2022: Risk Assessment or Internal Audit?
According to ISO 27001 Risk Assessment precedes Internal Audit as part of the standard’s management system lifecycle, which aligns with the Plan-Do-Check-Act (PDCA) model, but with refinements in terminology and structure.
Updated Process Flow in ISO/IEC 27001:2022:
Plan:
Understand the organization and its context (Clause 4.1)
Determine needs and expectations of interested parties (Clause 4.2)
Define the ISMS scope (Clause 4.3)
Conduct the Risk Assessment (Clause 6.1.2)
Determine risk treatment plans and select controls from Annex A (2022 edition: 93 controls grouped under 4 themes)
Do:
Implement the selected controls and operational procedures (Clause 8.1)
Manage risks and apply treatments
Check
Monitor, measure, and evaluate ISMS performance (Clause 9.1)
Conduct Internal Audits (Clause 9.2) to assess control effectiveness and compliance
Act
Corrective actions and continual improvement (Clause 10.1 and 10.2)
The Risk Assessment feeds the entire ISMS: it defines what needs to be secured, how risks will be treated, and what controls are justified. Internal Audits then evaluate whether the controls—based on that risk context—are effective and being followed.
So, in short:
Risk Assessment first to guide what needs to be done
Internal Audit later to check whether it was done right
This sequence ensures alignment with Clause 6 (Planning) before performing Clause 9 (Performance Evaluation) activities, such as auditing.
Key Differences at a Glance:
Understanding these differences is crucial for organizations aiming for ISO 27001 certification or maturing their overall governance, risk, and compliance (GRC) frameworks.
Can Risk Assessment Be Automated?
The short answer is: Yes, to some extent—but with caveats.
Risk Assessment, especially in large organizations, is often manual, repetitive, and resource-intensive. This naturally leads to the question: can we automate it? The idea is attractive, particularly for environments like cloud infrastructure or enterprise IT systems that are constantly changing.
What Can Be Automated?
Several components of Risk Assessment can benefit from automation:
Asset Discovery and Classification: Tools like CMDBs (Configuration Management Databases) and cloud inventory scanners can automatically identify and classify assets.
Vulnerability Scanning: Security scanners (e.g., Nessus, Qualys, OpenVAS) continuously detect known vulnerabilities across systems, providing real-time risk input.
Threat Intelligence Integration: Automated feeds can provide up-to-date information on emerging threats relevant to the organization's technology stack.
Risk Scoring: Algorithms can calculate risk scores based on likelihood and impact, using predefined formulas and thresholds.
Control Mapping: Tools can match risks to applicable controls (e.g., ISO 27001 Annex A, NIST SP 800-53) and suggest remediation paths.
Reporting and Dashboards: Automation can generate real-time dashboards and compliance reports, allowing for continuous visibility into risk posture.
What Still Requires Human Oversight?
Despite these advancements, human judgment remains critical in several areas:
Contextual Interpretation: Automation lacks business context. For instance, a critical vulnerability on a test server may not pose the same risk as one on a production server containing customer data.
Risk Appetite Evaluation: Only business leaders can define acceptable levels of risk based on strategic objectives.
Treatment Decision-Making: Choosing between mitigating, accepting, transferring, or avoiding a risk often involves legal, financial, and strategic considerations.
Residual Risk Assessment: Understanding the effectiveness of controls and what risk remains after implementation cannot be fully automated.
The Balanced Approach: Augmented Risk Assessment
Instead of asking whether Risk Assessment can be fully automated, a better question might be: how can we augment human-led risk assessments with automation to improve efficiency and accuracy?
The answer lies in a hybrid model:
Use tools for data collection, analysis, and monitoring.
Rely on experts for decision-making, context, and strategy.
This model not only saves time but also makes Risk Assessments repeatable, auditable, and scalable—especially useful for fast-paced or highly regulated industries.
Automate their risk identification and scoring processes
Integrate vulnerability scanners and threat intel feeds
Map risks to control frameworks like ISO 27001, NIST, CIS
And provide expert guidance on risk treatment and remediation strategies
Whether you're building a cloud-native application or preparing for ISO 27001 certification, our approach blends automation with strategic insight—ensuring you’re not just compliant, but secure by design.
To Summarise:
While Risk Assessment and Internal Audit are often mentioned in the same breath, they are structurally and strategically different. Risk Assessment is the proactive compass that points your organization in the right direction, while Internal Audit is the rearview mirror, confirming whether you stayed on course.
And per ISO 27001’s best practices, the ideal sequence is clear:
1️⃣ Risk Assessment first
2️⃣ Then control implementation
3️⃣ Followed by an Internal Audit.
Can Risk Assessment be automated? Yes—but only partially. Automation enhances the process, but expert insight still drives real security outcomes.
✅ Automate asset discovery & vulnerability detection
✅ Integrate threat intelligence feeds
✅ Generate dynamic risk scores
✅ Map risks to compliance frameworks (ISO 27001, NIST, etc.)
🎯 We blend automation with expert guidance to build scalable, audit-ready security programs that actually reduce risk—not just tick checkboxes.
As tech evolves, so will security compliances. You can't always afford last minute evidence collection.
