What it asks for. The organisation must conduct penetration testing on defined systems or components at a defined frequency.
In practice. Doing this well means a risk-based testing programme covering internet-facing services, critical applications and internal networks, using qualified testers with agreed rules of engagement, and retesting to confirm fixes. Auditors expect the test schedule, scope documents, reports and remediation tracking. CIS Control 18 covers penetration testing, and DORA requires threat-led penetration testing for certain financial entities. Cloud and identity configurations deserve testing alongside traditional infrastructure.
Common gaps. Scopes are often narrowed to avoid embarrassing findings, and remediation is not verified. Testing tends to focus on infrastructure while business logic in applications goes untested. Tests are also sometimes timed only around audits rather than after significant changes.