The Cybersecurity Topical Requirement: What You Need to Know

As the data landscape grows in sophistication, it’s important to understand the current environment and implement processes to protect your organization. Based on global feedback, the Institute of Internal Auditors (IIA) recently released its Cybersecurity Topical Requirement, aiming to address pervasive risks. The guide serves as a baseline function for internal audit teams to assess cybersecurity.  

Key Takeaways  

• The Cybersecurity Topical Requirement, introduced by the Institute of Internal Auditors (IIA), establishes key practices for organizations to assess their cybersecurity. 
• The requirement enhances internal audit services by maintaining consistency and quality, while also helping organizations build confidence among stakeholders. 
• Best practices for complying with the requirement include developing comprehensive cybersecurity strategies and policies, conducting risk assessments, defining clear governance roles, continuous monitoring of emerging threats, securing networks and endpoints, and performing ongoing employee training. 

What Are the 2026 Topical Requirements

The Cybersecurity Topical Requirement was first issued in February of 2025 and will go into effect on February 5, 2026. The IIA defines the topical requirement as a cornerstone in determining the potential scope of an internal audit engagement, covering aspects of governance, risk management, and control processes. The Cybersecurity Topical Requirement is required when providing assurance over a specific area, and it is designed to provide structure and consistency for high-risk, frequently audited areas. 

The Purpose of Topical Requirements  

Topical requirements are not designed to replace risk assessments, professional judgement, or provide a detailed step-by-step approach to execute internal audit engagements. Instead, the purpose of topical requirements is to enhance the consistency and quality of internal audit services, strengthen internal audit functions amid the evolving risk landscape, and raise the quality and professionalism of the internal auditor’s performance. By implementing the topical requirements, internal auditors can:  

• Maintain consistency and quality in engagement performances  
• Build confidence among stakeholders  
• Increase the focus on resource investments  
• Strengthen the International Professional Practices Framework’s (IPPF) ongoing relevance  

Applying Topical Requirements  

To remain compliant with the Global Internal Audit Standards, internal auditors must implement the topical requirements. Conformance is mandatory for assurance services and recommended for advisory services. Topical requirements are applicable when:  

• The subject of an engagement is in the internal audit plan  
• Identified while performing an engagement  
• The subject of an engagement request is not on the original internal audit plan  

The Cybersecurity Topical Requirement  

The Cybersecurity Topical Requirement provides a consistent, comprehensive approach to assessing the design and implementation of cybersecurity governance, risk management, and control processes. These three key elements help internal auditors evaluate and assess an organization's baseline level of cybersecurity maturity.  

• Governance: Determine if organizations have an updated cybersecurity strategy, strong policies, clear roles, and effective stakeholder engagement 
• Risk Management: Assess if the organization can effectively manage cybersecurity risks through assessments, cross-functional involvement, and incident response plans 
• Controls: Evaluate if the organization has implemented cyber controls for systems, data, and IT systems to determine if the organization has key security measures in place, such as encryption, patching, and network controls 

Best Practices to Adhere to the Cybersecurity Topical Requirement 

By following these best practices, internal auditors are better able to assess cybersecurity and guide organizations toward a more secure future.  

Cybersecurity Governance Best Practices  

Create Cybersecurity Strategy and Oversight 

Creating a formalized cybersecurity strategy enables effective governance and resource allocation.  

Maintain Policies and Procedures  

Regularly updating policies and procedures helps organizations strengthen controls and adapt to evolving threats.  

Define Roles and Skills Assessments 

Clearly defining roles and performing skill assessments helps efficiently align personnel with cybersecurity objectives.  

Engage Stakeholders  

Engaging with senior management, legal, HR, and vendors allows you to address vulnerabilities and emerging threats proactively.  

Cybersecurity Risk Management Best Practices  

Conduct a Comprehensive Risk Assessment  

Conducting a comprehensive risk assessment provides a complete understanding of cyber risk processes across IT, HR, legal, operations, and finance departments. 

Establish Clear Accountability  

Designating teams to manage risks can help better monitor, report, and escalate cybersecurity risks.  

Train Employees  

Providing periodic risk awareness training sessions, such as simulated phishing campaigns, can educate employees, helping them recognize and respond to future threats.  

Create an Incident Response Plan 

Implementing an incident response and recovery plan urges organizations to have procedures in place to detect, contain, recover, and analyze incidents.  

Cybersecurity Control Processes Best Practices 

Perform Audits and Manage Talent  

Performing internal audits evaluates the effectiveness of controls, and talent management helps maintain technical cybersecurity competencies.  

Continuously Monitor  

Ongoing monitoring and reporting help identify emerging threats and improve cybersecurity.  

Manage System Lifecycles and Configuration  

Integrating cybersecurity with IT asset lifecycles helps manage user-access, configurations, and patching. 

Secure Networks and Endpoints 

Creating secure infrastructure via network controls like firewalls, segmentation, VPNs, and endpoint security.  

Implementing Professional Guidance for Enhanced Cybersecurity 

Implementing these best practices can help you better manage cybersecurity risks and adhere to the Cybersecurity Topical Requirement as a whole.  

The importance of seeking professional advice should not be overlooked. Working with an experienced internal auditor, cybersecurity expert, or IT professional enables organizations to identify system gaps to enhance their security, ultimately keeping their sensitive information safe. 

At EisnerAmper, our cyber risk team has decades of experience and diligently works to enable clients with the resources, tools, and experience to transform their cybersecurity processes. To learn how our team can help you implement the Cybersecurity Topical Requirement, contact us below.