The NovaSync team held various positions in the Enterprise Reliability Organization (ERO), including NERC CIP audit and compliance oversight roles at WECC and NERC. Collectively, we found that the story of the audit started long before any auditors actually walked through the door. By the time the audit team arrived onsite, we already had a pretty good idea of how the week would go. The paperwork told part of the story, but what really made the difference was how prepared the entity was for the audit itself.
Great preparation wasn’t about scrambling to put together binders of documentation at the last minute. It was about whether the NERC compliance program was woven into daily operations, whether SMEs could confidently demonstrate how their controls worked, and whether evidence was consistently displayed from start to finish. It’s very difficult to fake that kind of readiness and auditors can spot it pretty quickly. In this first part of our NERC CIP Audit Series, we are going to share some best practices and auditor insights on what happens before, during, and after a NERC CIP audit.
What Auditors Expect Before Arrival
The NERC CIP audit is a structured process, but contrary to popular belief, is not designed to trip you up. By the time your organization received your formal Notice of Audit, the NERC CIP audit wheels have already been spinning. The Region has likely performed an Inherent Risk Assessment and potentially completed an Internal Controls Evaluation as well. The auditors have started reviewing Request for Information (RFIs) submissions, compliance narratives, and other evidence packages that have been provided by the entity being audited. This is the first impression between the Regional audit team and the entity being audited.
Here’s some of the basic concepts the audit team is looking out for:
Consistency – If your change management policy says approvals must happen within five days, but your evidence shows approvals happening weeks later, that’s a problem. Policies and evidence artifacts should align to tell the same story.
Traceability – We want to see the thread that connects a requirement to the procedure, the procedure to the evidence, and the evidence to the responsible person. If that chain breaks anywhere, the processes aren’t clear, or the processes are clearly not being followed, it raises questions.
Readiness – Even before the audit team meets your Subject Matter Experts (SMEs), they’re working behind the scenes to assess alignment to your documentation. If we sense a disconnect, we’ll test it.
When an entity sends an audit package that’s clear, consistent, and logically organized, it sets the tone for the entire audit. When it’s rushed, contradictory, or incomplete, we know we’re in for a long couple of weeks.
The Most Common Pitfalls Before the Audit
From our experience, we noticed that most NERC CIP compliance program breakdowns weren’t due to malicious intent or lack of effort. They were due to poor or unclear processes and inadequate preparation. Let’s cover some of the gaps that came up again and again from our experience in the field:
Evidence Scattered Everywhere all at Once
One of the biggest challenges running a NERC CIP compliance program is staying organized. Some teams kept screenshots in SharePoint, access logs in email threads, and policy updates on a manager’s personal shared drive. By the time the audit came around, they had to play digital hide-and-seek to piece everything together.
If evidence wasn’t clear or provided in a coherent manner, the audit team had to spend more time looking through evidence and that extra review time would usually reveal more issues. If they could review evidence and get reasonable assurance quickly, then the audit team didn’t have to dive into the evidence as deeply.
SMEs Brought in Cold off the Bench
One of the most uncomfortable moments in an audit happens when we ask an SME a simple question about their process, and they look surprised like a deer in headlights. We would be lying if we didn’t say this happened frequently. Sometimes SMEs had never seen the submission that their compliance team put together for them. That disconnect usually leads to contradictory answers, and after a few contradictions, we dig deeper.
The “Month Before” CIP Scramble
Many entities waited until their audit notification letter to start gathering evidence. That meant assembling three years worth of logs and records in just a few weeks. The problem is, if you discover missing data or process failures at that point, it’s already too late. By then, the gaps are obvious and will likely require multiple RFI’s and follow-up discussions.
Compliance by Binders
We have experienced entities who believed compliance lived in paper binders, glossy, tabbed, color-coded binders. But if the binders didn’t reflect what was happening in the field, they were useless. Auditors always test whether paper aligns with practice. Sometimes when an SME was handed a binder and told to read out loud, it was blatantly obvious that there was misalignment. This would lead to more questions from the auditors about the disconnect between their binder and the actual compliance program.
Best Practices That Separate the Strong from the Struggling
Now, let’s flip the script. Here’s what the well-prepared entities did that impressed auditors and made the entire audit process much smoother for everyone:
Conducting Mock Audits
The best organizations treated audits like fire drills. They brought in internal review teams or even third-party experts to walk through their documentation and evidence packages exactly as auditors would. These dry runs revealed gaps early, when there was still time to fix them.
Mock audits didn’t just expose weak spots in documentation; they gave SMEs practice in explaining their processes. That confidence carried over into the real-world audit.
Building a Culture of Continuous Compliance
Entities that lived in a “continuous compliance” mindset never seemed rattled by audit notifications, mock audits, or even the real thing. They didn’t wait for the letter to start collecting evidence. They documented changes, tracked approvals, and logged access events in real time. By the time the audit came around, they weren’t scrambling, they were simply packaging up what they already had.
Keeping SMEs in the Loop
The entities that performed best, always ensured their SMEs were aligned with the compliance narratives being told. Before an audit, they sat down with engineers, IT/OT staff, and operators to review what had been submitted. That way, when the questions came, SMEs weren’t caught off guard, they were speaking from a position of knowledge and alignment.
Showing, Not Telling
Auditors aren’t impressed by polished PowerPoints. What we want to see is evidence in action. When entities could pull up real-time system logs, walk us through approval workflows, or show us live configurations, it created trust. It demonstrated that compliance wasn’t theoretical, it was operational.
Former Auditor’s Perspective on “Audit Psychology”
One thing entities rarely realize is that audits are as much about psychology as they are about paperwork. Auditors pay attention to body language, tone, and confidence.
When compliance staff talked over SMEs or became highly defensive, it made us wonder if something was being hidden. When SMEs contradicted each other, it suggested a lack of coordination. But when staff answered questions clearly, admitted when they didn’t know something, and pulled evidence quickly, it gave us confidence.
Audits aren’t adversarial by design. But they often became adversarial when preparation was poor. Entities that treated auditors like partners in cyber risk reduction typically had better outcomes.
How Automation Changes the Game
Several years ago, when RSAWs haven’t declared early retirement yet, most NERC CIP compliance managers spent hours chasing down screenshots, manually cross-referencing logs, and updating endless spreadsheets. Entire weekends were lost to formatting evidence packages. Some of the best audits we have been on are the ones that were the most prepared. Today, automation is reshaping the NERC compliance process. NERC CIP GRC Platforms like NovaSync centralize evidence collection, tie documentation directly to requirements, and capture changes as they happen. That means by the time the audit notification arrives, much of the work is already done.
Instead of frantic evidence hunts, compliance teams can walk into the audit with a single source of truth. For auditors, this creates a smoother, more efficient process. For entities, it reduces stress and the risk of errors. Being audit ready every day for every requirement is earned through proactive planning and practicing compliance in real-time.
The Value of Preparation
At the end of the day, preparation isn’t about impressing auditors. It’s about protecting your organization and the grid from cyber threats with a methodical cybersecurity program. A CIP violation doesn’t just result in penalties, sanctions, and fines, it damages your reputation as a steward of our power grid.
The entities that thrived during audits were the ones that deeply understood this. They weren’t preparing for auditors, they were building resilient NERC GRC programs that could stand up to scrutiny at any time. The audit just validated all the hard work.
Getting Ready for the Audit
As former NERC CIP auditors, we can tell you this: the story of your audit is written long before the first interview begins. If your evidence is consistent, your SMEs are prepared, and your compliance program runs continuously, the audit feels less like a trial and more like a validation.
Preparation doesn’t eliminate findings, remember no entity is perfect. But it does shape the tone of the audit and the trust level between you and the auditors. And in our experience, that trust made all the difference.
The next part of this series will walk you through the NERC CIP audit itself, discussing what really happens once the CIP auditors arrive, how evidence is tested, and what separates smooth audits from painful ones.