Topic starter
25/10/2026 11:04 am
TL;DR: Mock audits for NERC CIP-015 can fail when independence, feed-placement rationale, and anomaly evaluation cannot withstand challenge, according to Nozomi Networks. Audit readiness depends on proving that those judgments are consistent, documented, and defensible.
Editorial analysis by NHI Mgmt Group, based on content published by Nozomi Networks: “NERC CIP-015 in Practice #8: INSM Audit Readiness and Running a Mock Audit”.
Key questions
Q: Why does poor documentation create audit risk in NERC CIP-015 monitoring programmes?
A: Because the auditor is not just checking whether documentation exists.
Q: Where do NERC CIP-015 controls fail in practice when anomaly evaluation is informal?
A: They fail when the organisation relies on ad hoc judgement, incomplete protocol knowledge, or overloaded reviewers who cannot explain why a flagged event was or was not escalated.
Q: What should teams do first when a NERC CIP-015 programme has not yet been tested by audit?
A: Start with an independent mock audit that is run by someone outside the programme design team.
Practitioner guidance
- Run the mock audit independently Use a reviewer who did not design the CIP-015 programme and, where possible, has real auditor experience so the exercise surfaces weak assumptions instead of confirming them.
- Document the risk-based feed rationale Record why each network point was selected for monitoring, what scope it covers, and how that decision maps to the requirement language rather than to convenience.
- Stress-test anomaly evaluation questions Require the team to explain what counts as an anomaly, how it is evaluated, what further action follows, and why the decision is defensible under audit scrutiny.
Bottom line: The article’s central risk is that a monitoring programme can look complete while still failing under audit because its rationale and evidence trail are weak.
Glossary terms: Mock Audit, Risk-Based Approach, Anomaly Detection, Electronic Security Perimeter
Explore further
View Full Forum → | NHI Foundation Course → | Our Services → | Read the full analysis →
This topic was modified 7 days ago by NHI Mgmt Group
27/10/2026 7:17 pm
Audit readiness fails when the programme audits itself. A mock audit run by the same people who designed the control will always understate the weak points that matter most. Independence is not a formality, it is the mechanism that surfaces hidden assumptions about scope, evidence, and anomaly handling. Practitioners should treat separation of duties as the foundation of any credible assurance exercise.
A question worth separating out:
Q: When should utilities treat a mock audit as a governance exercise rather than a technical drill?
A: They should do that whenever the standard depends on judgement, defensible rationale, and evidence quality rather than on purely measurable thresholds. CIP-015 is a good example because the most important questions are about why decisions were made, how they were documented, and whether the team can defend them to an auditor.
👉 Read our full editorial: NERC CIP-015 mock audits hinge on independence and evidence
This post was modified 7 days ago by NHI Mgmt Group