The Top Audit Findings TraceSecurity Saw in 2025

Introduction 

Every year brings its own flavor of audit findings, but 2025 felt different. Not because the FFIEC and NCUA expectations suddenly changed, they did not, but because the gap between what institutions say they are doing and what they are actually operationalizing became more visible than ever. Across dozens of assessments throughout the year, a few patterns showed up repeatedly.  

These were not edge-case weaknesses or obscure technical gaps. They were foundational control breakdowns hiding behind otherwise mature-looking programs. If 2024 was about documentation maturity, 2025 was about execution reality. And heading into 2026, institutions that fail to shift from “policy-first” thinking to “control-first” implementation are likely to feel increasing pressure from regulators. Let’s break down the most common findings, and more importantly, what they signal for the year ahead. 

1. Vendor Risk Management Exists… But Isn’t Alive 

Most institutions we assessed had vendor management programs on paper. Risk tiering existed. Due diligence checklists were completed. Contracts were stored. But the living, breathing part of vendor risk, ongoing monitoring, was often missing. 

We repeatedly saw annual reviews skipped or treated as a checkbox exercise, no documented reassessment when vendor services changed, cybersecurity posture not reevaluated after incidents, and critical vendors lacking updated control validation. In many cases, a vendor categorized as “high-risk” had not been meaningfully reassessed in years. 

What this means for 2026: 
Regulators are increasingly focused on third-party operational resilience. Static vendor files will not cut it anymore. Expect stronger scrutiny on whether monitoring actually drives decision-making, not just documentation. Vendor risk programs need to move from administrative workflows to risk-informed oversight. 

2. Access Reviews Were Performed… But Not Trusted 

User access reviews were almost universally present, but the quality of those reviews varied widely. We saw reviews completed by managers without system knowledge, certifications signed off in minutes, privileged accounts overlooked, service accounts ignored entirely, and no documented challenge process. In short, the review process existed, but it did not always produce confidence. This creates a silent exposure: institutions assume least privilege is enforced when, in reality, access creep is accumulating. 

What this means for 2026: 
Expect more emphasis on review integrity rather than review frequency. Regulators are beginning to care less about whether a review happened and more about whether it was meaningful. Access governance will need to evolve beyond “spreadsheet certification” toward risk-aware validation. 

3. Incident Response Plans Were Written… But Not Exercised 

Nearly every institution had an incident response plan. Far fewer had tested it in a way that resembled reality. Common themes included: tabletop exercises that were overly scripted, no executive participation, no technical validation of response timelines, ransomware scenarios never fully walked through, and lessons learned not being fed back into updates. Plans looked strong on paper, but confidence dropped quickly when asked, “When was the last time this was pressure-tested?” 

What this means for 2026: 
Preparedness will be judged by muscle memory, not documentation. Institutions that fail to demonstrate realistic testing, especially around cyber extortion scenarios, may face deeper examination. Response capability is becoming as important as preventive controls. 

4. Patch Management Metrics Looked Good… But Reality Lagged 

Many institutions reported strong patching timelines, yet when sampled more closely, exceptions were not tracked centrally, end-of-life systems remained in production, third-party platforms fell outside patch SLAs, and critical vulnerabilities sat unresolved under “risk acceptance.” This disconnect often came from fragmented ownership between IT, security, and operations. The metrics told one story. The environment told another. 

What this means for 2026: 
Superficial compliance metrics will carry less weight. Regulators are increasingly interested in whether patch programs reduce actual exposure, not just meet internal timelines. Asset visibility and vulnerability prioritization will matter more than raw patch speed. 

5. Business Continuity Planning Was Compliance-Driven 

Business continuity programs were widespread, but often treated as an annual requirement rather than a strategic resilience tool. We frequently observed recovery assumptions not tied to real-world dependencies, testing focused on documentation walkthroughs, third-party recovery not validated, and cyber disruption scenarios separated from BCP. In practice, many institutions were prepared for physical disruptions but less prepared for operational outages caused by cyber events. 

What this means for 2026: 
The line between cybersecurity and business continuity is disappearing. Expect increased pressure to integrate cyber disruption into continuity planning, not treat it as a separate discipline. Resilience will need to reflect modern threat realities. 

6. Risk Assessments Were Updated… But Not Used 

Perhaps the most subtle pattern was this: risk assessments were being refreshed regularly, but not always driving decisions. We saw high risks persisting without mitigation timelines, control gaps identified repeatedly across cycles, no clear linkage between risk ratings and investment priorities, and board reporting focused on scores rather than action. The assessment existed. The governance loop did not always close. 

What this means for 2026: 
Risk management will be evaluated based on outcomes, not process maturity. Institutions that can’t demonstrate how identified risks translate into strategic action may find their programs viewed as informational rather than operational. 

Looking Ahead: The Shift from “Program” to “Performance” 

The overarching lesson from 2025 was not that institutions lacked cybersecurity programs. It was that many programs have not fully crossed the bridge into operational effectiveness. Policies exist. Frameworks are mapped. Assessments are conducted. But in many environments, the controls behind those structures are still developing. 

For 2026, the trajectory is clear: monitoring over documentation, validation over assumption, and execution over policy. Institutions that focus on making controls real, lived, tested, and measurable will be best positioned as expectations continue to evolve because the future of FFIEC and NCUA oversight is not about whether a program exists. It is about whether it works when it matters most.