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Auditing ISO 27001 Clause 9: Performance Evaluation

October 29, 2026 Posted by 3FOLD ISO 27001, Lead Auditor No comments

PR373 · ISO/IEC 27001:2022 ISMS Lead Auditor11 min read

Auditing ISO 27001 Clause 9: Monitoring, Internal Audit and Management Review

Clause 9 asks three things: that the organisation measures something meaningful and evaluates the results, that it audits itself against its own requirements and the standard, and that top management reviews the system against a defined list of inputs and takes decisions. It is where an ISMS’s real condition shows, and it should be audited early rather than last.

3FOLD TRAINING · CQI and IRCA Approved Training Partner (ATP 6039853) · Course Approval No. 2889
3
Things Clause 9 asks
3
Sub-clauses: 9.1, 9.2, 9.3
2
Worked findings: one Major, one Minor

In this guide

  • Audit ISO 27001 Clause 9 early, not last
  • 9.1 — monitoring, measurement, analysis and evaluation
  • 9.2 — internal audit
  • 9.3 — management review
  • A worked ISO 27001 finding on Clause 9.1
  • A worked ISO 27001 finding on Clause 9.3
  • Major or minor on ISO 27001 Clause 9
  • Where ISO 27001 Clause 9 connects
  • Where to go next: more ISO 27001 Lead Auditor exam preparation

Clause 9 asks three things: that the organisation measures something meaningful and evaluates the results, that it audits itself against its own requirements and the standard, and that top management reviews the system against a defined list of inputs and takes decisions. It is where an ISMS’s real condition shows, and it should be audited early rather than last.

The worked findings on this page are invented, and so are the organisations in them. They are written to show how a finding is built and graded, not to catalogue the findings you should expect.

Audit ISO 27001 Clause 9 early, not last

The commonest planning mistake is to work through the clauses in order and arrive at Clause 9 with an hour left. That is backwards.

Clause 9 tells you where to look everywhere else. An internal audit report from six months ago is a map of the organisation’s own weak points, drawn by someone who knows the business. A management review that shows a metric moving the wrong way for three cycles tells you which control to test. Read the Clause 9 records early and let them direct the rest of the audit.

It also tells you something no other clause does: whether the organisation can find its own problems. An ISMS with a functioning Clause 9 and several minors is in better health than one with a silent Clause 9 and nothing found.

9.1 — monitoring, measurement, analysis and evaluation

The clause requires the organisation to determine what needs monitoring and measuring, the methods to be used to ensure valid results, when the monitoring is performed and by whom, and when results are analysed and evaluated and by whom. Documented information on the results is required.

Clause 9.1 b) adds that the methods selected should produce comparable and reproducible results to be considered valid. It is worded “should”. Weak ground for a finding on its own, but it is part of 9.1 b), not a note.

Two tests do most of the work here.

Ask what the measures are for. A measure that nobody could act on is a number, not a measure. Ask what a bad result would look like and what would happen next.

Follow the chain from measurement to evaluation. Most organisations measure. Fewer analyse. Far fewer evaluate — that is, decide what the analysis means. The clause requires all three and names who does each, so the gap is usually visible in a document that records numbers and no conclusions.

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9.2 — internal audit

9.2.1 requires internal audits at planned intervals providing information on whether the ISMS conforms to the organisation’s own requirements and to the standard, and is effectively implemented and maintained. That first limb is what makes an organisation’s own procedures auditable, and the last is what stops an internal audit being a document check.

9.2.2 requires an audit programme that includes frequency, methods, responsibilities, planning requirements and reporting; that considers the importance of the processes concerned and the results of previous audits; that defines the criteria and scope of each audit; that selects auditors and conducts audits so as to ensure objectivity and the impartiality of the audit process; that reports results to relevant management; and that is evidenced by documented information.

And one distinction that decides a good many Clause 9.2 findings. Clause 9.2.1 states what internal audits are conducted to provide information about: whether the ISMS a) conforms to the organisation’s own requirements for it and to the requirements of the standard, and b) is effectively implemented and maintained. Both limbs are requirements. Cite 9.2.1 where what the audits deliver is the problem; cite 9.2.2 where the programme’s frequency, methods, responsibilities, planning requirements or reporting are; and cite 9.2.2’s objectivity limb only where who audited what is the problem. Three questions, three citations — and reaching for objectivity because it is the phrase that comes to mind is how a good finding gets written against the wrong requirement.

On auditor independence, one form of words is safe: 9.2.2 requires auditors to be selected and audits conducted so as to ensure objectivity and the impartiality of the audit process. “Auditors must not audit their own work” is the practical consequence and a sound thing to look for, but it is not the standard’s phrasing. And auditor competence is Clause 7.2, not 9.2.

9.3 — management review

Three sub-clauses, and the middle one is a list you can audit against directly.

9.3.1 requires top management to review the ISMS at planned intervals. 9.3.2 lists the inputs: the status of actions from previous reviews; changes in external and internal issues; changes in the needs and expectations of interested parties; feedback on information security performance including trends in nonconformities and corrective actions, monitoring and measurement results, audit results and the fulfilment of objectives; feedback from interested parties; results of risk assessment and the status of the risk treatment plan; and opportunities for continual improvement. 9.3.3 requires the results to include decisions on continual improvement and any need for change to the ISMS, with documented information available as evidence of those results.

Audit it as a checklist, because it is one. Take the most recent review record and tick off the inputs. A missing input is one of the cleanest findings to write, because there is nothing to interpret.

Then read the outputs. 9.3.3 requires decisions. A record that lists attendance, presentations given and papers noted, with no decision anywhere, does not meet it.

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A worked ISO 27001 finding on Clause 9.1

Dunmore Software has defined six information security measures and publishes a monthly dashboard.

StatementThe organisation has not evaluated its information security performance or the effectiveness of the information security management system.
Objective evidenceThe measurement plan (MEA-02) defines six measures, the method for each, a monthly collection frequency and a named collector, and states that results are to be analysed and evaluated quarterly by the information security steering group. Twelve monthly dashboards for the period were produced, each recording the six values. No record of any analysis or evaluation was produced for any of the four quarters. Steering group minutes for the four quarters record the dashboards as received and contain no conclusion on performance. Measures 2 and 5 have been outside their stated tolerance for six consecutive months, and no record of any consideration of that was produced.
RequirementISO/IEC 27001 Clause 9.1 requires the organisation to evaluate the information security performance and the effectiveness of the information security management system.
GradeMajor — no evaluation has been performed in any quarter of the period, so the requirement is unperformed rather than inconsistently performed; two measures have been outside tolerance for six months with nothing on the record considering it, which shows what the absent evaluation has cost.

Note which requirement this cites. The organisation did determine when results would be analysed and by whom, so the parts of 9.1 about determining are met — and a finding written against them would be defeated by producing MEA-02. What is not met is the requirement to evaluate. Reading the clause to the end before choosing the limb is what makes the difference.

A wording point that matters when you write the requirement out. At 9.1, 9.2.2, 9.3.3 and 10.2 the current text says documented information shall be available as evidence; the word retain belongs to 6.1.2, 6.1.3, 6.2, 7.2, 8.2 and 8.3. Quoting the older verb in a finding hands the auditee something to argue about.

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A worked ISO 27001 finding on Clause 9.3

Thornbury Mutual holds management reviews half-yearly, chaired by the chief operating officer, with decisions recorded.

StatementOne required input was not considered in the most recent management review of the information security management system.
Objective evidenceManagement review records MR-09, MR-10, MR-11 and MR-12 were examined, covering four cycles. MR-09, MR-10 and MR-11 each record consideration of all the required inputs. MR-12 contains no item on opportunities for continual improvement; the standing agenda item was carried but not addressed, and the chair confirmed the item was deferred for time. All four records show top management in attendance and contain decisions on changes to the ISMS.
RequirementISO/IEC 27001 Clause 9.3.2 g) requires the management review to include consideration of opportunities for continual improvement.
GradeMinor — the management review process operates, is attended by top management, considered every required input in the three preceding cycles and produces decisions; the omission is a single input in a single cycle.

A finding that cannot supply all three — the statement, the objective evidence and the requirement — is not defensible, and the auditee can reasonably challenge it. A nonconformity missing its evidence or its criterion is the commonest defect in a written finding, and the first thing an auditee will push on. The order the three are written in varies — some material teaches requirement first, some statement first — and what matters is that all three are present, specific and traceable.

Major or minor on ISO 27001 Clause 9

The grading test does not change by clause — evidence and reach, never how serious the failure feels, with related minors capable of adding up to a major. The Clause 8 page in this set states the test in full. What changes by clause is what falls on each side of the line.

  • Major territory: no internal audits performed; no audit programme at all, or one with no defined method, responsibilities or reporting route; no management review held; monitoring defined but never evaluated; a review with no decisions across cycles.
  • Minor territory: some required inputs missing from a review that otherwise works; one internal audit late against the programme; one measure without a stated method.
  • Escalation: a pattern of internal audits that never find anything, in an organisation where you are finding things, is worth pursuing at 9.2.1 — whether the audits are delivering the information the clause requires — and, where the cause turns out to be who audits what, at 9.2.2’s objectivity limb.

And an opportunity for improvement is not a way round a weak Clause 9 finding. If the requirement is unmet, it is a nonconformity; if it is met and could be done better, that is advice the organisation may take or leave.

Where ISO 27001 Clause 9 connects

ConnectionWhat it gives you
Clause 5.1Whether top management attends and decides — the most useful available evidence about commitment
Clause 6.2Whether the objectives set there are actually monitored, which 6.2 requires
Clause 10.2What happened to the nonconformities the internal audits raised — the subject of the next page in this set
Clause 7.2Internal auditor competence, which lives there and not in 9.2
A.5.35 and A.5.36Independent review of information security, and compliance with the organisation’s own policies — controls that overlap Clause 9 without being it

Frequently asked questions about auditing ISO 27001 Clause 9

What does ISO 27001 Clause 9 require?

Monitoring, measurement, analysis and evaluation; internal audits at planned intervals under a defined programme; and management review by top management against a listed set of inputs, producing decisions. Documented information is required for each.

Does ISO 27001 Clause 9.2 say auditors cannot audit their own work?

Not in those words. Clause 9.2.2 requires auditors to be selected and audits conducted so as to ensure objectivity and the impartiality of the audit process. That is the requirement to cite; not auditing your own work is the practical consequence of it. Auditor competence sits at Clause 7.2, not here.

What must an ISO 27001 management review consider?

Status of previous actions; changes in issues; changes in interested-party needs; feedback on information security performance including nonconformity trends, measurement results, audit results and objective fulfilment; feedback from interested parties; risk assessment results and treatment plan status; and opportunities for continual improvement.

How often must ISO 27001 internal audits and management reviews happen?

At planned intervals. The standard sets no frequency, so the organisation’s own plan becomes the criterion, and an organisation that missed its own interval has failed its own requirement.

Is a dashboard enough for ISO 27001 Clause 9.1?

No. The clause requires results to be analysed and evaluated, by named people at defined times. Numbers with no conclusions meet the measuring half and not the evaluating half.

Where to go next: more ISO 27001 Lead Auditor exam preparation

  • Auditing Clause 8: operational planning and control
  • Auditing Clause 10: nonconformity and continual improvement
  • The clause map: what each clause asks, on one page
  • Where the evidence lives: clauses matched to records

3FOLD TRAINING is a CQI and IRCA Approved Training Partner, ATP number 6039853. Its ISO 27001 Lead Auditor training course is the CQI and IRCA Certified ISO/IEC 27001:2022 Lead Auditor (Information Security Management Systems) Training Course. The course identification number is PR373. Both the partner approval and the course certification are on 3FOLD TRAINING’s Approved Training Partner record, and any provider’s certified courses can be looked up in CQI and IRCA’s own directory of certified courses and approved training partners. The course page carries the schedule and what the course includes. If you would rather ask a person first, use the course enquiry form.

Booking a PR373 course? See the schedule, trainers and what’s included.

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CQI and IRCA Approved Training Partner · ATP 6039853 · PR373, Course Approval No. 2889
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