From Reactive to Proactive: Turning 2025 Findings into Your 2026 Audit Roadmap

Annual audit planning often starts in the wrong place. Teams spend Q1 responding to exam reports, updating policies, and closing out 2025 findings, then turn around and build a 2026 audit plan that looks a lot like last year’s – same areas, similar timing, a few tweaks around the edges. Findings are treated as boxes to check and files to archive, not as core inputs into how the internal audit function should deploy its time and credibility over the coming months.

If you want to move from reactive to proactive, that has to change. A truly risk-based 2026 audit roadmap starts with your 2025 results: exam and supervisory letters, internal and external audits, BSA/AML reviews, model validations, compliance monitoring, IT assessments, and partner bank reviews. When you systematically consolidate those outputs, group them into themes and root causes, and map them back to your audit universe and risk assessments, they stop being a backlog of issues and become a blueprint for where audit should focus next.

Step 1: Build a Consolidated 2025 Issues Inventory

The starting point for a proactive 2026 audit roadmap is a single, consolidated view of what went wrong in 2025. Most organizations have findings scattered across exam reports, internal audits, monitoring summaries, BSA/AML reviews, IT assessments, and partner bank memos. Until you pull those into one place, you are planning with partial information.

Collect All 2025 Sources

Begin by listing every source of formal and informal issues from 2025, including:

• Regulatory exams and supervisory letters
• Internal audit reports and follow-up memos
• External audit and independent review reports (BSA/AML, sanctions, IT/cyber, model validation, SOX where applicable)
• Compliance monitoring, QA/QC, and testing reports
• IT/cybersecurity and penetration test reports
• Significant incident post-mortems and root cause analyses

You want every place where someone outside the business line has documented a gap, weakness, or concern.

Normalize the Findings into a Single Log

Next, standardize everything into one structure – regardless of source format. At minimum, capture for each issue:

• Source (exam, internal audit, BSA review, monitoring, partner bank, etc.)
• Date issued
• Risk/issue rating (translate into a common scale: e.g., Critical/High/Medium/Low)
• Summary of the issue (short, risk-focused description)
• Impacted area (product, process, system, or audit universe element)
• Root cause (if already identified)
• Owner / responsible function
• Target remediation date and current status (open, in progress, closed, risk accepted)

This becomes your 2025 issues inventory – a single spreadsheet or tracker that you can sort, filter, and report from.

Distinguish Documentation Gaps from Real Risk

Not all issues are equal. Some are about formatting or documentation; others point to genuine control failure or customer harm. As you normalize the log, flag:

• “Paper” issues – e.g., policy not formally approved, missing documentation, incomplete minutes where the underlying control is functioning.
• Substantive risk issues – e.g., late or missed SARs, incorrect disclosures, sanctions control weaknesses, inaccurate reporting, complaint handling failures, access issues.

Capture Repeat and Cross-Cutting Issues

Finally, identify where similar problems are appearing in multiple places:

• Tag issues that are repeats of prior exam or audit findings.
• Tag issues that appear across multiple lines, products, or reviews (e.g., change management, documentation quality, vendor oversight).

These tags will matter when you prioritize. Repeat and cross-cutting issues are strong candidates for deeper, multi-year audit coverage, not just one-time follow-up.

By the end of Step 1, you should have a clean, consolidated 2025 issues inventory that you can sort by severity, theme, owner, and area. That inventory becomes the backbone for the next step: grouping findings into themes and root causes, so you can stop managing issues one by one and start understanding the underlying patterns driving your 2026 audit priorities. 

Step 2: Turn Individual Findings into Themes and Root Causes

With a consolidated 2025 issues inventory in place, the next step is to stop looking at findings one by one and start asking: what do these issues have in common? Regulators, partner banks, and Boards care less about how many individual findings you have and more about whether you understand the patterns and are addressing the underlying causes.

Cluster Findings into Logical Themes

Start by grouping issues that clearly relate to the same risk area, process, or control family. The goal is to create a short list of themes, not a new version of the issue log. Common examples include:

• Governance & oversight
  • Unclear ownership of controls, weak committee charters, inconsistent Board reporting, limited challenge from governance bodies.
• Policies, procedures & documentation
  • Out-of-date policies, procedures not aligned to actual practice, undocumented exceptions, missing approvals.
• BSA/AML & sanctions
  • CDD/EDD gaps, alert backlogs, SAR/CTR timeliness issues, sanctions screening deficiencies, model validation findings.
• Consumer protection / UDAAP / disclosures
  • Inconsistent or unclear disclosures, fee practices not aligned to terms, marketing claims not supported by product design.
• Third-party / fintech oversight
  • Incomplete due diligence, weak ongoing monitoring, unclear roles between institution and partner, gaps in contract controls.
• IT / cyber / change management
  • Access control issues, incomplete logging, changes implemented without testing or sign-off, weak incident response.
• Operations & servicing
  • Backlogs in key processes, recurring processing errors, exceptions not monitored, poor documentation of decisions.

You can group by product (e.g., card, deposit, lending), channel (digital vs. branch), or partner program where it makes sense, but keep the list of themes manageable—ideally 5–10 major buckets, not 30.

Perform Simple, Practical Root Cause Analysis

Once you have themes, ask what is really driving them. Root cause analysis does not have to be complicated; it does need to be honest. For each theme, look across the issues and ask:

• Is this primarily a design problem?
  • Controls, policies, or systems were never set up correctly.
• Is this an execution problem?
  • Controls exist on paper but are not followed or monitored.
• Is this a staffing or training problem?
  • Volumes outpaced capacity; staff do not understand expectations.
• Is this a data or systems problem?
  • Poor data quality, limitations in legacy systems, manual workarounds.
• Is this a governance/change management problem?
  • Changes rolled out without proper review; roles and escalation paths unclear.

You can capture this in a simple table: Theme → Primary Root Cause(s) → Example Issues. You are not trying to replace full-blown root cause exercises for every finding; you are identifying the dominant drivers so you can plan audit coverage accordingly.

Separate One-Off Issues from Structural Weaknesses

Not every theme deserves the same weight in your roadmap. Some clusters reflect isolated events; others reveal structural weaknesses that cut across products and functions. As you review each theme, consider:

• Breadth – Does it affect one product/process, or multiple lines and programs?
• Depth – Are findings minor (documentation tweaks) or significant (control failures, regulatory criticism, customer harm)?
• Trajectory – Is this the first time you’ve seen it, or has it appeared in multiple years or sources?

Themes that are broad, deep, and recurring should drive meaningful 2026–2028 audit coverage, not just one more follow-up test.

Document Themes Clearly for Later Use

Finally, write down each theme in a way you can reuse with management, the Board, and external stakeholders. For each theme, capture:

• A short, plain-language description of the theme.
• The key processes/products/programs affected.
• The likely root causes (design vs. execution vs. staffing vs. systems vs. governance).
• A rough count of related 2025 issues and their typical severity.

By the end of Step 2, you should have moved from a long list of isolated 2025 findings to a concise set of themes and root causes. Those themes are what you will now map onto your audit universe and risk assessments in Step 3, so your 2026 audit roadmap is explicitly grounded in the real patterns regulators and auditors have already surfaced.

Step 3: Map Themes to the Audit Universe and Risk Assessment

Once you have your 2025 themes and root causes, the next step is to connect them to specific auditable areas and your existing risk assessments. This is where you turn “what went wrong last year” into a structured view of where audit needs to focus next.

Link Each Theme to Concrete Auditable Units

Start by mapping each theme to the elements of your audit universe. You want to answer, very specifically: Which audits, if executed well, would meaningfully address this theme? For each theme, identify:

• Primary auditable units
  • Examples: BSA/AML program, sanctions program, digital onboarding/KYC, transaction monitoring, marketing & disclosures, complaint management, vendor/fintech oversight, IT access management, change management, collections, servicing, credit underwriting, model risk.
• Supporting or related units
  • Areas where the same root cause appears in a different context (e.g., weak change management across both IT and operations; documentation gaps across multiple product lines).

Add a column in your issues or themes tracker that lists the linked audit universe elements for each theme. This makes it easier to see which units carry the heaviest weight of 2025 criticism.

Cross-Check Themes Against Your Risk Assessments

Next, overlay your existing risk ratings. The objective is to ensure that areas with significant 2025 findings and high risk ratings are front and center in your roadmap. For each auditable unit tied to a theme:

• Pull its residual risk rating (High/Medium/Low, or equivalent) from:
  • Compliance risk assessment
  • BSA/AML and sanctions risk assessment
  • Enterprise or operational risk assessment
  • IT/cyber risk assessment, where applicable
• Note any risk trend indicators (increasing, stable, decreasing) and key drivers.
• Highlight mismatches, for example:
  • High-risk rating + multiple 2025 findings + limited audit coverage in recent years.
  • Low/moderate risk rating + concentration of substantive 2025 findings (may signal that the assessment is stale or understated).

If you discover a theme with material findings in an area still rated “low” residual risk, that is a signal to revisit and update the risk assessment before finalizing the roadmap.

Identify Coverage Gaps and Overlaps

Now, compare what your themes and risk assessments are telling you against your recent and planned audit coverage. For each auditable unit impacted by 2025 themes, ask:

• When was this area last audited or independently reviewed?
• What was the scope and depth (full program vs. narrow process review)?
• Were findings from the last audit aligned with 2025 themes (or did something new emerge)?

From this, flag:

• Coverage gaps
  • High-risk areas or theme-heavy areas not audited in the last 24–36 months.
  • Key processes (e.g., third-party oversight, change management, complaints) that have never had a stand-alone audit.
• Coverage overlaps
  • Areas that are audited frequently but do not show significant new findings, while other areas with substantial themes have minimal coverage.

This analysis helps you rebalance your 2026–2028 plan so you are not over-auditing legacy comfort zones and under-auditing newer or more problematic areas.

Prioritize Auditable Units by Theme and Risk Impact

At this point, you should be able to see which audit areas sit at the intersection of:

• High or increasing residual risk
• Significant or repeat 2025 themes/findings
• Limited or dated audit coverage

These are your priority candidates for 2026 (and early 2027) audit work. Document them in a simple summary, for example:

• Auditable unit
• Linked 2025 themes/root causes
• Current residual risk rating and trend
• Last audit date / scope
• Priority level for 2026–2028 (e.g., Must-cover in 2026; 2027; 2028)

This gives you a defensible, risk-based explanation when someone asks, “Why are we auditing this now?”

By the end of Step 3, you have moved from abstract themes to a risk-ranked list of specific audit areas that need attention, grounded in both your 2025 findings and your risk assessments. The next step is to turn that ranked list into a multi-year audit roadmap (2026–2028) that sets clear coverage and frequency expectations—rather than another one-year plan built from habit. 

Step 4: Design Your 2026–2028 Audit Roadmap

With your priority audit areas identified, the next move is to stop thinking in one-year increments and build a multi-year audit roadmap. Regulators and partner banks increasingly expect to see not just “what you’re doing in 2026,” but how that fits into a broader plan to address your risk profile and 2025 themes over time.

Set Clear Coverage and Frequency Standards

Start by defining how often different types of risk should be audited. This gives you a consistent framework instead of renegotiating every year. A common approach (adjust for your size and complexity):

• High-risk areas / heavy 2025 themes
  • Full-scope audits every 12–18 months.
  • Focused reviews or remediation validation in between if needed.
• Moderate-risk areas
  • Full-scope audits every 24 months.
  • Thematic or limited-scope reviews when there are specific concerns or changes.
• Low-risk areas
  • Periodic coverage through thematic reviews or reliance on other assurance (e.g., compliance monitoring, SOC reports, vendor audits).

Overlay 2025 themes on top of this: areas with significant or repeat findings may warrant temporarily higher frequency, even if the underlying inherent risk is only moderate.

Document these standards so that when someone asks, “Why are we auditing this every 18 months?” you can point to a consistent, risk-based rule—not a one-off judgment call.

Build a Simple 2026–2028 Coverage Grid

Next, translate your standards and priorities into a multi-year view. A basic spreadsheet is enough with the following columns:

• Residual risk rating and trend
• Linked 2025 themes (yes/no, brief descriptor)
• Last audit or independent review date
• Planned coverage by year (2026, 2027, 2028)
  • Mark as Full-scope / Focused / Validation-only / Thematic / Not planned

Then, populate the grid:

• Place must-cover areas (high risk + heavy 2025 themes + long since last audit) into 2026.
• Schedule other high-risk areas into late 2026 or 2027 so you stay within the 12–18 month cadence.
• Slot moderate- and low-risk areas into 2027–2028 to maintain coverage without overloading 2026.

You should be able to look at the grid and see a rational pattern: high-risk and theme-heavy areas appearing more often; lower-risk, stable areas on a more relaxed, but still defined, cycle.

Decide What Absolutely Belongs in the 2026 Plan

Now refine the 2026 slice of the roadmap. For each candidate area, ask:

• Does this area have significant or repeat 2025 findings that need remediation validation?
• Is it rated high residual risk, or marked as increasing?
• Is there an upcoming exam, partner bank review, or major product/system change that elevates its priority?
• Has it been more than your target frequency since the last meaningful review?

Areas that score “yes” on multiple questions are your non-negotiables for 2026. Others can be staged into 2027–2028, as long as you remain within your coverage standards.

This is also the moment to reconcile the plan with reality: you will likely have more “desirable” audits than capacity. Use the roadmap to make explicit choices about what gets done in 2026 versus later, instead of letting those decisions happen informally throughout the year.

Use 2027–2028 to Address Broader Structural Themes

The multi-year view is particularly useful for structural issues that cannot be fully addressed in a single year. For example:

• Change management weaknesses affecting multiple systems and products.
• Third-party/fintech oversight gaps across several partners.
• Documentation and policy alignment issues spanning multiple business lines.

Rather than trying to audit everything in 2026, design a sequence over 2026–2028 that might look like:

• 2026: Deep-dive audit of enterprise change management + focused review of one or two high-risk programs.
• 2027: Audits of additional programs where change risk is significant + follow-up on 2026 remediation.
• 2028: Thematic review tying together lessons and confirming that the structural weaknesses have been addressed.

Documenting this progression shows regulators, partner banks, and the Board that you have a plan to address root causes over time, not just to chase individual findings.

Sanity-Check the Roadmap Against Capacity

Before finalizing, stress-test the roadmap:

• Estimate effort (e.g., small/medium/large) for each 2026 engagement.
• Align total planned work with realistic internal hours and any planned co-sourcing/outsourcing.
• Adjust by:
  • Combining closely related scopes where appropriate.
  • Reclassifying some 2026 audits as more focused or validation-only.
  • Moving lower-priority work into 2027 while keeping within coverage rules.

By the end of Step 4, you have evolved from a one-year audit calendar into a multi-year, risk-based plan that explains when and how you will address 2025 themes. The next step is to design 2026 engagements that explicitly validate remediation, so you can demonstrate that prior issues were not only “closed” in a tracker but actually fixed in practice.

Step 5: Build 2026 Engagements That Explicitly Validate Remediation

Once you know which areas are on the 2026 roadmap, you need to make sure the engagements themselves are designed to answer a key question: Did we actually fix what went wrong in 2025? Too many plans list the “right” areas but then run generic audits that never clearly tie back to specific prior findings or remediation commitments.

Make Remediation Validation a Stated Objective

For any area with material 2025 findings, remediation testing should not be implied—it should be written into the scope. For each 2026 engagement linked to 2025 issues, add objectives such as:

• Verify that corrective actions implemented in response to 2025 exam/audit/monitoring findings are in place and operating as designed.
• Confirm that underlying root causes (governance, design, execution, staffing, systems) have been addressed, not just documentation updated.
• Assess whether residual risk has changed as a result of remediation (e.g., control environment improved, repeat issues reduced).

Putting this in the planning memo and audit program makes it clear to management, the Board, and regulators that 2025 findings are a core driver of 2026 work, not an afterthought.

Trace Each 2025 Issue to Specific Controls and Tests

Avoid vague references like “we’ll follow up on prior issues.” Instead, build a simple mapping before fieldwork:

• List the relevant 2025 issues (by ID/description) for the auditable unit.
• Identify the specific controls or process steps that were supposed to change.
• Translate those into testable procedures, such as:
  • Review updated policies/procedures and governance approvals.
  • Walk through revised processes with control owners.
  • Test a sample of transactions before and after the change.
  • Confirm system/rule changes were implemented and are functioning.

This mapping can live as a table in your planning documentation and referenced in workpapers. It gives you a direct line from “2025 finding” to “2026 test.”

Prioritize Depth for Repeat and High-Severity Findings

Not all 2025 findings warrant the same intensity. For engagements where prior issues were high severity or repeat:

• Allocate more testing depth (larger samples, more scenarios, multiple time periods).
• Consider a two-stage approach:
  • Stage 1: Early limited-scope review focused solely on remediation status.
  • Stage 2: Later full-scope audit that incorporates remediation plus broader control design and effectiveness.
• Be explicit in your report about whether:
  • The issue is fully remediated and effective,
  • Partially remediated (some elements implemented, others lagging), or
  • Not effectively remediated and should be treated as a repeat finding.

For less severe or “paper” issues, validation can be narrower (e.g., focused documentation review) while still being clearly documented.

Time Audits to Match Remediation Reality

If you audit too soon, you will only prove that the fix isn’t live yet; too late, and you miss an opportunity to course-correct. For each 2025 issue tied to a 2026 engagement:

• Confirm management’s target completion date for remediation.
• Schedule validation work after that date, but with enough runway left in 2026 to address residual gaps if the fix is weak.
• Where remediation is phased (e.g., policy change first, then system changes), plan your testing to align with key milestones rather than a single “all-or-nothing” review.

Document this timing logic in your audit plan and, where appropriate, in Board or committee materials. It shows you are calibrating validation to when controls should realistically be in place.

Label and Track Remediation Validation in Reporting

When you issue 2026 reports, make it easy for stakeholders to see how they tie back to 2025:

• Include a section or appendix listing prior issues validated in this audit, with clear status (remediated / partially remediated / not remediated).
• Update your central issues log to reflect the outcome of validation testing, with cross-references to the 2026 audit report.
• Where issues remain open or partially fixed, assign new or revised action plans and due dates, and consider whether to elevate risk ratings or governance attention.

This closes the loop between your issues management process and your audit program, and it gives regulators and partner banks a clean narrative: we heard the criticism, we implemented fixes, and we independently tested them.

By the end of Step 5, your 2026 audit plan should contain engagements that are explicitly designed to validate 2025 remediation, not just revisit areas in name only. The next step is to synchronize this roadmap with compliance monitoring, issues management, and Board reporting, so your use of 2025 findings shows up consistently across all three lines of defense – not just in internal audit. 

Step 6: Synchronize the Audit Roadmap with Monitoring, Issues, and Board Reporting

A strong 2026 – 2028 audit roadmap should not live in isolation. Regulators and partner banks expect a coherent story across your three lines of defense: how monitoring, internal audit, and issues management work together, and how that story is communicated to leadership and the Board. Step 6 is about making sure your roadmap is reflected everywhere else your risk program shows up.

Align the Roadmap with Compliance Monitoring and QA

Internal audit is not the only line testing controls. If monitoring and QA are looking at one set of risks while audit is focused on another, you will end up with duplication in some areas and blind spots in others. Use your 2025 themes and 2026 roadmap to:

• Coordinate coverage by risk area
  • Identify where monitoring can provide more frequent, lighter-touch reviews between full-scope audits (e.g., monthly sampling of specific disclosures, complaints, or KYC files).
  • Clarify which themes are primarily monitored by Compliance/Operations and which require independent audit attention.
• Avoid overlap and test fatigue
  • Where monitoring already provides strong, recurring coverage, design the 2026 audit to rely on that work (after testing its quality) rather than re-performing the same testing.
  • Communicate the 2026 audit calendar to Compliance and Operations so they can time monitoring reviews to complement, not conflict with, audit fieldwork.
• Feed monitoring results back into the roadmap
  • If 2026 monitoring detects deterioration or new issues in a themed area, use that as an input to adjust your audit timing or scope mid-year.

Integrate the Roadmap with Issues Management

Your issues log should tell the same story as your audit plan. If the tracker says a high-risk issue will be validated by internal audit in 2026, that validation should be clearly visible in your roadmap and engagement plans. Practical steps include:

• Tag issues with planned validation engagements
  • For each 2025 issue, add fields that indicate:
    • The 2026 (or later) audit that will validate remediation.
    • The expected quarter or month of that audit.
  • Track validation status explicitly
    • When a 2026 audit tests remediation, update the issues log with:
      • “Validated – effective,” “Validated – partially effective,” or “Not validated – repeat issue.”
      • Cross-reference to the audit report ID and date.
    • Use the roadmap to manage aged and repeat issues
      • For high- and critical-rated issues that are past due or have recurred, consider:
        • Pulling forward a planned audit into 2026 or early 2027.
        • Expanding the scope to include broader design and governance, not just the specific control that failed.

Make the Roadmap Part of the Board and Committee Story

Boards, Audit Committees, and Risk/Compliance Committees want to see that you are learning from 2025 and incorporating those lessons into 2026 work. The roadmap should show up clearly in your regular Board-level reporting. Consider:

• Summarize 2025 themes and link them to 2026 work
  • Include a simple table or slide that shows:
    • Key 2025 themes (e.g., BSA alert backlog, change management gaps, UDAAP/disclosure issues).
    • Related 2026 audits or reviews.
    • High-level status of remediation.
  • Show the multi-year view, not just a 2026 calendar
    • Provide a one-page roadmap that maps key auditable areas across 2026–2028, with icons or shading for:
      • Full-scope audits
      • Focused reviews
      • Remediation validation work
    • Report on progress against the roadmap, not just completed audits
      • In each Board/Committee pack, track:
        • % of 2026 plan completed vs. planned.
        • Any changes to the roadmap (e.g., new audits added due to incidents; others deferred and why).
        • Status of validation for major 2025 findings.

This elevates the conversation from “Here are the audits we did” to “Here is how we are using last year’s findings to systematically reduce risk over the next several years.”

Keep the Narrative Consistent Across Stakeholders

Finally, make sure the story you tell:

• To regulators and partner banks (in exams, due diligence, and program reviews),
• To your Board and committees, and
• Internally to senior management

All lines up:

• 2025 findings → themed and analyzed
• Themes → mapped to risk assessments and audit universe
• Roadmap → 2026–2028 coverage set and resourced
• 2026 audits → explicitly validate remediation and address root causes
• Monitoring and issues management → integrated into the same narrative

By the end of Step 6, your 2026–2028 audit roadmap should be embedded into monitoring, issues management, and Board reporting, not operating as a standalone document. The final step is to call out common mistakes to avoid and ensure your move from reactive to proactive planning does not get derailed by over-ambitious scopes, unrealistic capacity assumptions, or weak documentation of your methodology.

Common Mistakes When Using Findings to Shape the Audit Plan

Even with a solid framework, it is easy to fall back into old habits and end up with a 2026 plan that mentions 2025 findings but is not truly driven by them. Being explicit about common mistakes helps you avoid undermining an otherwise strong roadmap.

Treating Findings as a Checklist, Not a Signal

Many teams treat 2025 issues as a list to “clear” rather than as indicators of where the control environment needs deeper, sustained attention.

• Risk: You close items in the tracker but fail to address structural weaknesses; the same types of issues reappear in different forms.
• Avoid it: Use themes and root causes to determine where you need more frequent or deeper audit work, not just where you owe a follow-up test.

Copying Last Year’s Plan with Cosmetic Tweaks

A common shortcut is to start with the 2025 audit plan, change a few dates and titles, and call it “risk-based.”

• Risk: You over-audit familiar areas and under-audit areas where 2025 findings were concentrated or risk is growing (e.g., new products, partners, or digital channels).
• Avoid it: Build the 2026–2028 roadmap off your themes, risk assessments, and coverage gaps, then use last year’s plan only as a reference check.

Overloading 2026 and Ignoring Capacity

It is tempting to put every issue-driven audit into 2026 to “show progress,” especially after a tough exam or partner review.

• Risk: You create a plan that cannot be executed; scopes are watered down, timelines slip, and key engagements get deferred informally without a clear record.
• Avoid it: Use the multi-year roadmap to make explicit trade-offs. Prioritize 2026 for high-risk and repeat themes, and stage others into 2027–2028 based on your capacity.

Weak or Vague Linkage Between Findings and Audits

Some plans list high-level topics (“BSA audit,” “Compliance audit”) without clearly showing which 2025 findings they will address.

• Risk: Regulators, partner banks, and the Board cannot see how 2025 results drove 2026 coverage; you lose credibility when challenged.
• Avoid it: Document, for each 2026 engagement, the specific 2025 issues/themes it is intended to address and how remediation will be validated.

Confusing Remediation Validation with Full-Scope Audits

In some cases, teams either treat a narrow remediation check as if it were a full audit, or design a full audit but barely touch prior issues.

• Risk: Stakeholders may believe you have “re-audited” an area when you only checked one fix, or they may still not see clear evidence that key issues were tested.
• Avoid it: Be explicit in your planning and reporting:
  • Label engagements as full-scope, focused, or validation-only.
  • Clearly state which prior issues were tested and what you concluded.

Failing to Update Risk Assessments in Light of 2025 Findings

If risk assessments remain unchanged after significant 2025 findings, your roadmap may rest on outdated assumptions.

• Risk: Areas with substantive issues continue to be rated “moderate” or “low,” which undermines your claim that the plan is risk-based.
• Avoid it: Where themes are significant or recurring, refresh residual risk ratings before finalizing the roadmap and document the rationale.

Poor Documentation of Methodology and Rationale

You may have done thoughtful work behind the scenes, but if the method lives only in spreadsheets and emails, it is hard to defend.

• Risk: When examiners or partner banks ask, “How did you build this plan?” the answer looks ad hoc and retrospective.
• Avoid it: Maintain concise documentation of:
  • How you built the 2025 issues inventory.
  • How you developed themes and root causes.
  • How you mapped themes to the audit universe and risk assessments.
  • How that mapping drove your 2026–2028 roadmap and engagement design.

How RADD Can Help

Translating a year’s worth of exams, audits, and reviews into a clear 2026–2028 audit roadmap is a lot to ask of an internal team that is already stretched. RADD can step in as a practical partner to structure the work and deliver something you can defend to regulators, partner banks, and your Board.

We start by consolidating your 2025 exam, audit, BSA/AML review, monitoring, and partner bank findings into a single issues inventory, then distill those into themes and root causes. From there, we map those themes to your audit universe and risk assessments, identify true coverage gaps, and help you design a realistic 2026–2028 audit roadmap—showing what must be covered in 2026 and what can be staged into later years.

RADD can also help draft 2026 engagement scopes that explicitly validate remediation, align the roadmap with compliance monitoring and issues management, and prepare Board-ready materials that clearly show how 2025 findings drove your plan. The result is a risk-based audit roadmap that is structured, documented, and actually executable—not just a refreshed version of last year’s plan.

Conclusion

When you treat 2025 exam, audit, and monitoring results as a one-time cleanup exercise, you stay stuck in a reactive cycle – chasing findings, updating documents, and hoping the next review goes smoother. When you treat them as structured inputs into your 2026 – 2028 audit roadmap, they become something very different: a prioritized view of where your control environment is under strain, where governance needs to mature, and where internal audit can add the most value.

By consolidating 2025 issues into a single inventory, grouping them into themes and root causes, mapping those themes to your audit universe and risk assessments, building a multi-year roadmap, and designing 2026 engagements that explicitly validate remediation, you move from “checking the box” to a defensible, risk-based audit strategy. Layering that roadmap into monitoring, issues management, and Board reporting gives you a coherent story for regulators, partner banks, and your own leadership about how you are using last year’s lessons to reduce tomorrow’s risk.

If you want support turning your 2025 findings into a focused, executable audit plan, RADD can help.

Click Here to schedule a discovery call with RADD – to review your 2025 results, build a consolidated issues inventory, and translate those findings into a clear, documented 2026–2028 audit roadmap you can deliver – and confidently defend.