§ 04 · The register
Seven additions to your risk register before the next audit.
Each row maps a specific 2025–2026 capability to a control family that is now stale, the GRC framework where the staleness will be cited first, and the artifact a thoughtful auditor will start asking for. None of the artifacts are exotic. All seven are deliverable in a quarter if the trigger is named today.
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The new addition
Why · what auditors will ask
Framework
01
"Annual pentest" cadence is no longer reasonable.
Pentest On-Demand compresses a 35–100-day cycle into hours. SOC 2 CC7.1 and ISO 27001 A.8.8 ask for a vulnerability-management program "commensurate with risk." Continuous is now the commensurate cadence; annual is not. Expect language change in the auditor's request list, not the standard.
SOC 2 CC7.1 · ISO A.8.8
02
Threat model must name agentic offensive AI as a threat actor.
A threat catalog that stops at "external attacker · insider · nation-state" omits the actor that beat 9 of 10 human pentesters at $18/hr. ISO 27001 A.5.7 (threat intelligence) and the HIPAA Security Rule's 164.308(a)(1)(ii)(A) "accurate and thorough" risk analysis both require the model to reflect current capability. It does not.
ISO A.5.7 · HIPAA 164.308
03
Vulnerability-scan frequency belongs in days, not quarters.
CMMC SI.L2-3.14.1 and PCI DSS 11.3 set quarterly/annual floors. Floors are not ceilings; auditors will start treating the 2026 floors as 2014 floors. Document a continuous scanning cadence and the exception process for the windows where it doesn't run.
CMMC 3.14.1 · PCI 11.3
04
Vendor-pentest evidence must be dated, not annual.
Third-party risk programs that accept "vendor's last pentest report" satisfy SOC 2 CC9.2 and HIPAA 164.308(b) on paper. They no longer satisfy them in fact: a six-month-old report describes a network state two XBOW runs ago. Ask vendors when they last tested, not whether.
SOC 2 CC9.2 · HIPAA 164.308(b)
05
Use of an agentic pentester is itself a processing activity.
An agent reading production data is a data-processing activity under GDPR Art. 30 and a workforce-access event under HIPAA 164.308(a)(4). Sub-processor lists, BAAs, and the records-of-processing register all need a row that names the agent vendor, the data classes touched, and the retention.
GDPR Art. 30 · HIPAA 164.308(a)(4)
06
AI-system inventory must list offensive AI tooling under your control.
EU AI Act Title III dual-use scrutiny and NIST AI RMF GenAI Profile (NIST AI 600-1) §3 cyber-offense risks both need the inventory to identify any agentic offensive AI you operate. ISO 42001 A.6.1.4 (AI system impact assessment) is the right place to record the assessment.
EU AI Act · ISO 42001 · NIST AI 600-1
07
Insurability: your carrier's renewal questionnaire already has this row.
Cyber-insurance underwriters that didn't ask about agentic pentesting in 2024 will ask in 2026. Treat the renewal questionnaire as your forward-looking control catalog. The honest answers are usually "no" today; the roadmap answer is what the carrier wants to read.
Carrier policy · Sched. A