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Course Instructor: Ashish Revar

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cloud-securityauditgap-assessmentCIS

Cloud Security Audit: Gap Assessment, Remediation & Evidence Collection

A cloud security audit systematically compares an organisation's cloud posture against a standard (CIS Benchmark, NIST CSF, ISO 27001) to identify gaps. This article describes the audit process, evidence collection methods, and remediation tracking.

Ashish Revar3 July 202618 min read1 views

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Reference material

eBook
Cloud Security — eBook
v2026
Open resource
Cheatsheet
Cloud Security — Cheatsheet
v2026
Open resource
MCQ Bank
Cloud Security — MCQ Bank
v2026
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Question Bank
Cloud Security — Question Bank
v2026
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External references

AWS Config Documentation

AWS Config documentation covering managed rules, custom rules, remediation, and conformance packs.

CERT-In Empanelled Auditors List

CERT-In portal listing approved IS auditing organisations for Indian regulatory compliance.

AWS Audit Manager

AWS Audit Manager for continuous compliance evidence collection against frameworks.

ISO 27001:2022 Cloud Controls Mapping

ISO 27001:2022 with Annex A controls mapped to cloud security requirements.

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Purpose and Scope of a Cloud Security Audit

A cloud security audit has a different character from a traditional IT audit. Traditional audits examine documentation, interview staff, and sample configurations manually. Cloud audits can (and should) interrogate the cloud provider's API directly — every configuration is queryable, and the audit trail is in CloudTrail.

An audit may be:

  • Internal: Conducted by the organisation's own security or IT audit team
  • External: Conducted by an empanelled CISA (Certified Information Systems Auditor) or CERT-In-empanelled auditor
  • Regulatory: Mandated by CERT-In 2022 for Critical Information Infrastructure operators; by RBI for regulated entities; by SEBI for capital market participants

Audit Framework: The Four Phases

Phase 1: Scoping and Planning

Define:

  • Scope: Which accounts, regions, and services are in scope? (e.g., all AWS accounts in the production OU)
  • Standard: Which benchmark applies? (CIS AWS v3.0, ISO 27001:2022, NIST CSF 2.0, PCI-DSS v4.0)
  • Timeline: How long will evidence collection, analysis, and reporting take?
  • Tools: Prowler for CIS; AWS Config for continuous compliance; manual scripts for custom checks

Phase 2: Evidence Collection

Cloud audit evidence is collected from APIs, not interviews:

Evidence SourceWhat It ProvesHow to Collect
AWS IAM Credential ReportMFA status, access key age, password age for all IAM usersaws iam generate-credential-report
CloudTrail — last 90 daysRoot account usage, IAM changes, S3 policy changesAthena query on the CloudTrail S3 bucket
AWS Config Rules — compliance snapshotContinuous compliance status at point-in-timeConfig → Compliance Dashboard → Export
Security Hub — consolidated findingsAggregated findings from GuardDuty, Macie, InspectorSecurity Hub → Findings export (CSV/JSON)
VPC Flow LogsNetwork-level evidence of traffic patternsS3 query or Athena
S3 Bucket ACL exportPublic access status of all bucketsaws s3api get-bucket-acl for each bucket

A useful audit automation script collects all of the above and packages them into a ZIP archive with a hash manifest for evidence integrity.

Phase 3: Gap Analysis

Compare collected evidence against the chosen standard. The output is a gap table:

ControlStandard RequirementCurrent StateStatusRisk
CIS 1.5MFA on root accountMFA not enabled on rootFAILCritical
CIS 3.1CloudTrail in all regionsTrail exists for ap-south-1 onlyFAILHigh
CIS 3.9VPC Flow Logs enabledAll production VPCs have flow logsPASS—
CIS 1.14Access keys rotated < 90 days3 of 7 users have keys > 90 days oldFAILMedium

Phase 4: Remediation and Reporting

For each gap, the audit report must include:

  • Finding: What was found (with evidence reference)
  • Risk: Why it matters (what an attacker could do with this weakness)
  • Recommendation: Specific technical remediation steps
  • Owner: Who is responsible for remediation
  • Target date: When remediation will be complete

Continuous Compliance: AWS Config

AWS Config is a continuous compliance service that evaluates resources against defined rules (managed or custom):

RuleWhat It Checks
root-account-mfa-enabledMFA enabled on root account
cloudtrail-enabledCloudTrail active in all regions
s3-bucket-public-read-prohibitedNo S3 bucket allows public read
vpc-flow-logs-enabledFlow logs enabled on all VPCs
iam-user-no-policies-checkNo IAM users have directly attached policies
encrypted-volumesAll EBS volumes are encrypted

Config runs these rules continuously. Non-compliant resources appear in the Config dashboard in near-real-time. This transforms audit from a point-in-time event into a continuous process.

CERT-In Audit Requirements for Indian Organisations

Under CERT-In 2022 Directions, organisations owning/operating ICT infrastructure are required to:

  1. Conduct an annual information security audit by a CERT-In-empanelled auditor
  2. Implement recommendations within 6 months of the audit report
  3. Report audit findings to CERT-In as requested
  4. Maintain audit records for 1 year

CERT-In maintains a list of empanelled IS auditing organisations on their website. For cloud environments, the auditor should specifically assess:

  • CloudTrail coverage and log retention (180 days minimum per CERT-In 2022)
  • Access control configurations
  • Data encryption at rest and in transit
  • Incident response capability and the 6-hour reporting readiness

Evidence Integrity: The Auditor's Obligation

Audit evidence from cloud APIs is only valid if the auditor can demonstrate it has not been tampered with after collection. Best practices:

  • Generate a SHA-256 hash of each exported file at the time of collection
  • Store evidence in immutable storage (S3 with Object Lock, or offline archive)
  • Document the date, time, API endpoint, and credentials used for each collection
  • For CloudTrail log evidence: verify log file integrity using CloudTrail's digest files (aws cloudtrail validate-logs)