Not all findings are equal, and the difference is not severity of language - it is consequence. One category blocks your certificate, one imposes a deadline, and one carries no obligation at all. Knowing which you are looking at determines how you should spend the next week.
Major nonconformity
The serious one. Typically raised when:
- An entire required process or control is absent.
- A systemic failure means the management system is not achieving its intended outcome.
- Several related minor findings together indicate a breakdown rather than a lapse.
- A previously raised minor was never effectively corrected - repetition is itself evidence of a systemic problem.
Consequence: certification is withheld until it is resolved, or suspended if you are already certified. Resolution usually requires evidence of correction and effectiveness, often verified by a follow-up visit rather than a document review. Timelines are typically weeks, not months.
Minor nonconformity
A single lapse against a requirement, isolated rather than systemic - one missed access review, one policy past its review date, one sampled change without recorded approval.
Consequence: certification can normally proceed, subject to an accepted corrective action plan. You will be asked for root cause analysis, a plan with dates, and evidence at the next surveillance visit. The plan itself is usually due within 30 to 60 days.
The trap is treating minors as paperwork. A minor closed with "we have reminded the team" and no root cause analysis reliably reappears at the next audit - and a repeated minor is grounds for escalation to major.
Close findings properly, with the trail intact
GRC Copilot tracks findings, root causes, owners and due dates, and keeps the evidence of closure ready for the surveillance visit that will ask for it.
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Observations and opportunities for improvement
Not nonconformities. An observation typically flags something conforming today but trending toward a problem - a control that works but depends on one person, or a process that will not scale. An opportunity for improvement is advice.
Consequence: no formal obligation. But observations are the auditor telling you where they will look next year, and ignoring one repeatedly is how it becomes a minor. Recording them with a considered response - including "reviewed, no action, because..." - costs little and reads well.
SOC 2 uses different vocabulary
SOC 2 does not issue nonconformities. Instead:
- Exceptions - instances where a control did not operate as described. These appear in the report itself, visible to every customer who reads it.
- Qualified opinion - the auditor concludes controls were not effective in some respect. Roughly the equivalent of a major, and commercially significant because the report circulates.
The important difference: ISO nonconformities are resolved privately and the certificate is binary, while SOC 2 exceptions are published in the report. A minor issue you would shrug off in an ISO audit may need real attention if it will be read by prospects for the next twelve months.
Responding well
- Understand the finding precisely - which requirement, what evidence. Ask during the closing meeting rather than after the report arrives.
- Contain first where there is an active exposure, then correct.
- Find the real root cause. "The reminder was not sent" is a proximate cause; "the control has no owner and no scheduled trigger" is the root.
- Check for the same weakness elsewhere. Auditors sample; a finding in one system frequently exists in three. Extending the fix yourself is far better than having it found next year.
- Plan with dates and owners, and be realistic - a missed remediation date is worse than an honest longer one.
- Evidence effectiveness, not just action. The control must be shown operating, which for a quarterly control means waiting a quarter.
Challenging a finding
Legitimate grounds exist, and auditors do withdraw findings. A challenge works when it is factual: the evidence exists and was not provided during fieldwork, the requirement has been misread, the system is outside the agreed scope, or the finding is graded inconsistently with its own definition. It fails when it is an argument about how serious the issue feels.
Raise it during the closing meeting where possible - amending a draft report is straightforward, whereas disputing an issued one is a formal process. Be specific, provide the evidence, and accept the outcome gracefully either way; the relationship outlasts the finding.
Frequently asked questions
How many minors is too many?
There is no fixed threshold, but a cluster in one area invites escalation to a single major on the grounds of systemic failure. Distribution matters more than count.
Do observations have to be actioned?
No, but record your decision. An observation ignored for two cycles tends to return as a nonconformity.
Can a major be closed without a revisit?
Sometimes, through documentary evidence, but many certification bodies require a follow-up visit. Assume a revisit and plan the timeline accordingly.
Does a nonconformity become public?
Not for ISO - the certificate is what is published. SOC 2 exceptions do appear in the report your customers read, which changes the calculation.
Key takeaways
- Major blocks certification; minor imposes a corrective plan; observations carry no obligation.
- Repeated minors escalate - close them with real root cause analysis, not a reminder.
- SOC 2 exceptions are published to customers; ISO nonconformities are not.
- Challenge findings on facts, during the closing meeting, or accept them and move on.