April 2, 2026
Control the Controls: Preventing Compliance Drift
NERC audits test more than completed tasks — they test whether controls remain durable through change. This four-part series examines how compliance programs drift, what auditors actually evaluate, and why structured review and disciplined change management are the backbone of sustainable audit readiness.
Part 2 of a 4-part series
What are Auditors Auditing?
NERC audits do not fail because a patch was missed, an access review ran late, or a log wasn't retained. They fail because the system and its controls left a gap, and over time something slipped through the cracks. That is what auditors are actually evaluating and what they will ultimately judge.
There is a persistent narrative in the compliance community that NERC audits are designed to uncover mistakes. The image is familiar: auditors turning pages, searching for a missing signature, a misdated form, or an outdated policy header. That narrative influences how many organizations prepare. They respond by collecting more documentation, expanding evidence repositories, and tightening checklists.
In practice, most audits operate differently. Reliability is the real objective, and controls are what prevent gaps from forming so nothing has the opportunity to slip through.
Read Part 1 of this four-part series, where we explored how compliance programs drift over time. Here in Part 2, the focus shifts to what auditors are actually evaluating when they assess whether controls still hold.
The Importance of a Strong Audit Program
As discussed earlier, audits test whether controls remain durable through change. They are not primarily assessing whether a single task occurred on a specific date. They are evaluating whether the compliance program functions in a stable and repeatable way. The distinction matters. A document can confirm that something happened. It cannot, on its own, demonstrate that the underlying control is consistently understood, applied, and monitored.
Volume rarely substitutes for clarity. Large collections of evidence may signal effort, but they do not necessarily communicate structure. What tends to resonate more clearly is alignment: defined processes, consistent execution, traceable ownership, and documentation that reflects how work is actually performed.
Consistency is one of the clearest indicators of program strength. Auditors compare how similar requirements are handled across time, teams, and systems. Differences are not inherently problematic, but unexplained variation suggests that compliance may depend on individuals rather than on durable design. Controls that rely on institutional memory tend to weaken as organizations evolve.
Ownership carries similar weight. Auditors often probe beyond policy language to understand who is responsible for maintaining a control, how that responsibility is reinforced, and how lapses are detected. When ownership is visible and active, it signals that compliance is integrated into operations rather than layered on top of them.
How to Manage Your Controls in the Face of Change
Change is another recurring theme. Systems are upgraded, personnel transition roles, and processes adapt to operational realities. Findings frequently arise not because a change occurred, but because its effect on existing controls was not evaluated. Mature programs anticipate this dynamic and incorporate mechanisms to reassess whether controls remain aligned with current conditions.
This is where preparation shifts meaningfully. Instead of preparing only for compliance activities, strong organizations monitor the compliance program itself. They periodically confirm role assignments. They assess whether the control design still matches operational reality. They evaluate the quality and coherence of evidence. They solicit feedback from stakeholders to understand where friction or informal workarounds may be emerging.
These practices create a feedback loop. Controls are not assumed to remain effective simply because they once were. They are reviewed, refined, and strengthened over time. When auditors encounter a program that can explain not only what was done but also how the organization verifies its continued effectiveness, the conversation becomes more constructive.
Why Having an Audit Strategy Matters
Audits, at their core, test durability. They ask whether controls will continue to function under change, turnover, and operational pressure. Programs that understand this orientation prepare differently. They invest in clarity, governance, and periodic self-assessment rather than in expanding binders.
When compliance is treated as a living system rather than a static archive, the tone of an audit often shifts. It becomes less about identifying isolated gaps and more about evaluating the integrity of a program that is actively maintained. Preparing for that kind of audit requires a different mindset, one that prioritizes design, ownership, and continuous review over reactive documentation.
For more information about building a solid foundation with internal controls, read this article, "Internal Controls for More Than Just Compliance".
About the Author
Scott Crow is the Senior Business Systems Strategist – Energy & Utilities at AssurX, where he drives strategic innovation and technological transformation across the critical infrastructure landscape. With extensive experience in delivering IT/OT solutions, Scott specializes in tackling the most pressing cybersecurity and compliance challenges for the energy and utilities sector. His expertise lies in aligning technology with business objectives, seamlessly integrating people, process, and technology to develop solutions that optimize operational performance while safeguarding critical systems.
