I would say you should just write down a summary of what you really plan to do. Gap analysis is one part. Other aspects include: training of auditors, training of others, updating procedures and manual as determined by gap analysis, internal
audits to see whether gaps have been taken care of, management review of the audits, check that you do have a complete track record under the new version, schedule transition audit. This is real brief but to me should be the kind of thing the registrar is asking for.
