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Gap Description
Severity
Effort
1
3 open internal audit CAPAs — NC-001: no access review records; NC-002: incident response procedure incomplete (missing RACI, LGPD linkage); NC-003: no backup restoration test records. Unresolved NCs will prevent Stage 2 certification.
High
2–4 weeks each; close simultaneously
2
Control evidence gap — 3 of 93 controls verified. Stage 2 auditors will sample operational evidence (logs, screenshots, attestations) across all 93 Annex A controls. This is the single largest risk to certification.
Critical
6–8 weeks campaign May–Jul
3
Awareness & Training program not delivered. No training records exist. Clause 7.2 and Control A.6.3 require documented competence and awareness for all staff — absence is a straightforward Major NC at Stage 2.
High
3–4 weeks; by Jun 2026
4
18 gap assessment findings open (0 closed) — many are already remediated by completed Do-phase skills but the register has not been formally refreshed. Overstates open risk; needs an updated status picture for the Stage 1 auditor.
Medium
1–2 weeks refresh; May 2026
5
IS Objectives Register (Clause 6.2) not produced as a standalone artifact. Objectives exist informally but no formal register with measurable KPIs, owners, targets, and measurement frequency has been published.
Medium
1 week; CISO-led