In this Part 2 of our NERC CIP Audit series, we will focus on what happens during a NERC CIP audit. In Part 1, we explored behind the scenes of what happens leading up to a CIP audit, breaking down pre-audit activities and best practices. Now, we’re going to take a deeper look inside of the CIP audit itself and share best practices along with other valuable insights learned from real-world NERC CIP audit experiences.
When the audit week begins, there’s a certain energy in the room. For the entity being audited, it usually feels like the first day of finals week: a mix of anxiety, preparation, and anticipation. For auditors, it’s about getting down to business, verifying that what was submitted in the evidence package matches reality. Remember, auditors have a tight schedule and once they are completed, it’s on to the next.
The Audit Kickoff Meeting
Every audit begins with a kickoff meeting. This sets expectations for both sides of the engagement. The audit team introduces themselves, outlines the scope of the audit, and explains the schedule for the week. We review which standards and requirements will be in scope, what evidence sampling will look like, and how interviews will be conducted.
This meeting might feel like a formality, but it’s actually an early checkpoint. Auditors are already taking notes, watching how prepared your team looks, and setting the tone for the audit. This is a time for the auditors to meet the compliance team and other executives supporting the audit.
Sampling and Evidence Testing
Auditors don’t review every single piece of evidence you provide. Instead, instead they use sampling techniques. For example, if you’ve got 500 access approvals over three years, the auditor might randomly sample 10 of them. If those 10 random access approvals look consistent with provided documentation and the standard, that increases the auditor’s confidence that other records will be the same. If the audit team finds gaps in that sample, it will be expanded to more samples.
This is why evidence has to be consistent across the board. If your compliance team decides to cherry-pick your best examples of evidence, auditors will still select at random, and if they find inconsistencies, they’ll dig deeper.
Interviews with SMEs
One of the most important parts of the audit is the interview process. This is where the human side of compliance shows up. Policies and evidence can look airtight on paper, but if an SME can’t explain the process in plain language, it raises red flags.
Some questions you might expect from your auditors:
- “Walk me through how an access request is submitted and approved.”
- “Show me how you would revoke access for someone who left the company.”
- “Can you pull up the log for the last password change on this account?”
The auditors are not looking for rehearsed answers. In fact, scripted responses usually make auditors more suspicious. What they want is a clear, confident explanation that aligns with the evidence that was provided.
Following the Trail
Auditors are like investigators. If they see something that doesn’t line up, they follow the trail. One missing approval might lead to check other approvals. One SME who seems uncertain might lead the auditors to interview another SME in the same group.
This is where preparation matters most. If your compliance team and SMEs are aligned, the trail leads to consistent answers. If they’re not, the trail usually leads a more complex conversation about your compliance program and the standards being audited.
What Entities Often Get Wrong
Remember that an audit is a formal process for the Enterprise Reliability Organization (ERO) to audit and assess the NERC CIP standards. While some entities are very experienced in this process, a lot has changed over the years. As NERC and the ERO continue to improve NERC CIP audits, we wanted to share some of the current ways that entities trip themselves up during the audit itself.
Being Overly Defensive
Some entities treat the audit like a courtroom battle. They push back on every request, argue over interpretations, and act as if the auditors are the enemy. Even worse is when SMEs are silenced and a group of attorneys that don’t understand what NERC CIP compliance is, start arguing with the audit team. That posture doesn’t help. It creates tension and often makes the audit team dig deeper.
Preparing Compliance Movie Scripts
We’ve seen SMEs come into interviews with scripted answers, sometimes literally reading from a piece of paper. That almost always backfired. Auditors can tell when someone is reciting instead of explaining. What we want is to hear how the process really works, in the SME’s own words. The reason auditors take this approach, is to see if the people involved deeply in the compliance processes know and understand how their program is being run and managed.
Inaccessible Live System Evidence
Another common challenge our team used to see in the field, was when entities strictly relied only on their screenshots for evidence. Screenshots are fine for pre-submitted evidence, but when the auditors ask for live evidence requests, like pulling a log directly from a system, some entities froze. If you can’t demonstrate that evidence is available and accessible, it casts doubt on whether the screenshots provided are authentic or repeatable.
Best Practices for Success
While we have seen our fair share of challenges, we have also noticed some best practices that have helped entities shine during their NERC CIP audit. While we won’t expect everyone to be the same, these concepts have helped demonstrate remarkable NERC CIP compliance programs. Auditors are looking to trust but verify all the information provided is accurate and satisfies the language of the standards.
Transparency and Honesty
If something isn’t working perfectly, it’s better to admit it than to pretend otherwise. Auditors respect entities who said, “Yes, we missed the mark on this requirement, here’s why, and here’s what we’re doing to fix it.” Hiding issues almost always led to worse findings. More importantly it shows the culture of compliance isn’t established for transparency.
Empowered SMEs
The strongest entities let SMEs speak freely. They weren’t micromanaged by compliance managers or coached by attorneys into saying specific phrases they didn’t understand. They were comfortable explaining their processes, which made the audit feel natural like a conversation.
Show Control Effectiveness
Auditors aren’t just looking for paperwork, they’re looking for evidence that your controls actually work. If you can demonstrate how an access request flows through your system in real-time, that’s much more powerful than handing over a PDF of your policy.
Stay Organized Throughout the Week
Audits can be long and tiring. The best compliance teams kept daily agendas, made evidence easy to access, and maintained clear communication with auditors. That detailed oriented approach kept the process smooth and professional. After all, the audit team is most likely heading out to another audit shortly after completing the one they are on, so staying on track with timelines is very helpful.
The Psychology of the Audit Room
Auditors are human, and although they are there to audit to the strict language of the NERC standards, they also pick up on non-verbal cues.
When the audit is calm and confident, auditor tend to feel calm and confident as well. When compliance managers are frantic, defensive, or contradictory, it can raise alerts to the auditors.
One example of this is when an entity had SMEs who answered questions calmly, admitted when they didn’t know something, and pulled live evidence when requested as part of the conversation. Not adversarial and not trying to hide anything. The difference in auditor confidence was night and day.
How Automation Makes Audits Smoother
During our years as auditors, the NovaSync team watched compliance teams lose days to manual tasks. They had to pull logs from multiple systems, track evidence in many Excel documents, and chase down SMEs for routine screenshots. It was inefficient and stressful.
Today, NERC CIP GRC automation platforms like NovaSync make a huge difference because evidence is centralized, instead of searching all over SharePoint, inboxes, and shared drives. Evidence is then tied directly to specific controls to help tell the compliance story. NERC GRC platforms like NovaSync, also help with generating system reports on demand, reducing reliance on stale screenshots.
For auditors, this doesn’t just make things easier, it builds confidence. When you can show the auditors evidence in real time, consistently, without scrambling, it tells them your compliance program is embedded with an operational rhythm to sustain itself.
A Day in the Life: What the Audit Feels Like
To give you a sense of the day in a life during a NERC CIP audit, here’s how a typical audit day looks from the auditor’s perspective:
Morning: The auditors start with a quick meeting to review the day’s interviews. They might focus on requirements within a standard like CIP-005 (Electronic Security Perimeters) or CIP-007 (System Security Management).
Midday: Schedule interviews with SMEs, sample evidence, and request live demonstrations. This is usually the most intense part of the day.
Afternoon: The audit team regroups, reviews findings, and prepares follow-up questions. If something looked off during an interview, they’ll ask for more evidence.
At the end of the work day, the audit team sends the compliance manager a list of requests for information or clarifications. From experience, organized compliance teams get the auditors what they need quickly. The disorganized teams scramble late into the night, looking to find or create evidence that aligns with the auditor’s expectations.
Multiply this across four or five days, and you can see why preparation matters so much.
Closing out the NERC CIP Audit
From the auditor’s chair, the onsite (or virtual) audit is where preparation meets reality. If your documentation, evidence, and SMEs are aligned, the process feels straightforward. If they’re not, every inconsistency becomes a rabbit hole.
The audit isn’t meant to be adversarial, but it often becomes that way if entities come in unprepared or defensive. The best audits our team participated in were collaborative, with both sides working toward the same goal: ensuring the reliability and security of the bulk electric system.
While the audit itself technically isn’t the finish line, It’s more like the midpoint. After the audit, the findings, mitigation plans, and lessons learned shape the path forward. That’s where we’ll go in the next article, as we combine post audit lessons learned and our perspective on closing out a strong audit.