Cybersecurity Risk and the Strategic Role of Internal Audit

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Today’s organizations operate in an environment where cyber incidents are almost inevitable. Ransomware, phishing scams, cloud vulnerabilities, data leakage, and the exploitation of third-party systems continue to grow in complexity. These threats increasingly affect not only IT operations but business continuity, financial integrity, and organizational reputation. Against this backdrop, the internal audit function has become an essential partner in strengthening cybersecurity and maintaining enterprise resilience.

The Changing Threat Landscape

Cybersecurity incidents now represent core business risks. Attackers exploit system weaknesses, human lapses, and supply-chain connections to gain access to critical information. Several themes dominate the current landscape:

• Greater targeting of cloud environments and essential infrastructure
• Heightened regulatory reporting expectations
• More sophisticated ransomware and social engineering campaigns
• Increasing pressure on organizations to protect data and maintain operational continuity

This evolving environment demands structured oversight and clear lines of accountability across the enterprise.

Local Regulatory Context: What UAE Businesses Should Be Aware Of

For organizations operating in the UAE, understanding the regulatory environment is particularly important because requirements differ depending on whether the entity is located on the mainland or within a Free Zone.

• Mainland (On-shore) UAE:
  Most businesses fall under Federal Decree-Law 45 of 2021 (PDPL) for personal data protection, alongside sector-specific rules for areas such as healthcare and banking. All entities must also comply with federal cybercrime laws, including Federal Decree-Law 34 of 2021, which addresses hacking, unauthorized access, and misuse of systems.
• Free Zones:
  Some Free Zones have their own data protection laws, such as:

• DIFC Data Protection Law No. 5 of 2020
• ADGM Data Protection Regulations
• DHCC health data regulations

These operate independently of PDPL, although federal cybercrime laws still apply regardless of location.

• Dubai-specific Requirements:
  Under Dubai Law 15 of 2024, the Dubai Electronic Security Centre (DESC) oversees cybersecurity for government entities and certain private-sector organizations designated as critical. Internal audit teams must ensure alignment with DESC’s standards and reporting requirements.

For internal auditors, the key is understanding which jurisdiction applies to the business and ensuring that controls, documentation, and reporting processes reflect those obligations.

Internal Audit as a Cybersecurity Partner

Internal audit’s role in cybersecurity has expanded well beyond traditional compliance reviews. It now acts as a bridge between technical teams and senior leadership, ensuring that cyber risks are understood and managed in a way that supports the organization’s broader objectives.

Key responsibilities include:

• Identifying Risks: Understanding the organization’s technology landscape, critical assets, and potential exposures.
• Evaluating Controls: Assessing whether technical and procedural controls are designed effectively and functioning as intended.
• Ensuring Compliance: Verifying adherence to internal policies, regulatory requirements, and relevant standards.
• Monitoring Emerging Risks: Conducting periodic reviews that reflect evolving threats and changes in the business.
• Providing Insight: Communicating risk implications in practical, business-focused terms.
• Reviewing Third-Party Security: Examining vendor security measures and supply-chain dependencies.

This combination of assurance and advisory responsibilities helps shape a proactive cybersecurity posture.

Enabling Collaboration and Strong Cyber Governance

Effective cybersecurity depends on cooperation across functions. Internal audit strengthens this dynamic by fostering clear communication, supporting policy adherence, and promoting a culture where cybersecurity is recognized as a shared responsibility.

Organizations that integrate internal audit into planning, system changes, and incident response efforts often achieve faster issue resolution and improved risk visibility.

Practical Steps to Improve Cybersecurity Oversight

To support continuous improvement, organizations should consider:

• Involving internal audit early in cybersecurity strategy discussions and incident planning
• Using recognised frameworks such as the NIST Cybersecurity Framework or ISO 27005 to guide assessments
• Increasing the frequency of internal reviews in high-risk areas including cloud systems, endpoint protection, and third-party engagements
• Ensuring regular communication between IT security teams, risk management, and senior leadership
• Leveraging automation and analytics to enhance monitoring and reporting

These steps help create a structured, repeatable approach to cybersecurity assurance.

Strengthening Resilience for the Future

Strong cybersecurity requires more than technical defenses, it demands clear governance, disciplined oversight, and continuous learning. By combining structured risk assessment with a practical understanding of both operational and regulatory expectations, internal audit plays a central role in building resilience and preparing the organization for future threats.