ISO/IEC 27001:2022 Revision. Key Updates and What They Mean for Your Organisation

The internationally recognised information security standard ISO/IEC 27001 has undergone a significant revision (published October 2022) for the first time since 2013. This update is not just a routine tweak it reflects a transformed cyber threat landscape and aligns the standard with modern practices and the new ISO Harmonized Structure. Key changes include a major overhaul of Annex A security controls (from 114 controls down to 93, with 11 new controls added), adjustments to the risk management requirements (emphasising continuous and organisation wide risk oversight), and structural revisions to align ISO 27001 with the common framework used by other ISO management system standards.

For executives, IT managers, and compliance officers, understanding these changes is crucial. Below we break down the significance of the revision and practical steps to align your organisation with the updated ISO/IEC 27001:2022 standard.

Why the ISO/IEC 27001 Revision Matters

A Decade of Change: The last major overhaul of ISO 27001 was in 2013. Since then, digitalisation and cyber threats have evolved dramatically. Businesses now face more sophisticated cyber-attacks, widespread cloud adoption, and new data protection challenges that were not fully anticipated in the 2013 standard. The updated 2022 revision was deemed necessary to bring the standard up to date with modern cyber-attack and data breach scenarios and to ensure organizations can protect critical infrastructure and data in today’s environment.

Stronger Alignment with Modern Practices: ISO/IEC 27001:2022 aligns closely with the updated ISO/IEC 27002:2022 (the guidance for security controls), ensuring that recommended controls reflect current technology and threats. The revision also adopts ISO’s latest Harmonised Structure (HS) for management system standards, making it easier to integrate information security management with other standards like ISO 9001 (Quality) or ISO 22301 (Business Continuity). For leadership, this means information security is now structured in the same way as other business management processes, facilitating enterprise-wide governance and compliance.

Maintaining Trust and Compliance: From a strategic perspective, keeping your ISMS (Information Security Management System) aligned with the latest standard is critical for maintaining customer trust, regulatory compliance, and cyber resilience. Failing to transition by the deadline will result in certification expiry (current ISO 27001:2013 certificates expire in late 2025). In short, the revision underscores that information security is a continuously evolving responsibility  one that executives must champion to protect the organisation’s reputation and assets.

Updates to Annex A Controls: Modernised Security Measures

One of the most significant changes in ISO/IEC 27001:2022 is the overhaul of Annex A, which contains the reference list of security controls. These controls are the measures organisations choose (as applicable) to treat information security risks. The new standard introduces a streamlined, updated set of controls to address today’s threats.

• Reorganised Control Categories: Annex A’s controls have been regrouped from 14 domains into 4 thematic categories for clarity. Instead of 114 controls under the old structure, the 2022 revision features 93 controls organised into four main groups: Organizational (A.5), People (formerly “Personnel”, A.6), Physical (A.7), and Technological (A.8) control This reorganisation helps simplify control management and reflects how modern security practices are often cross-functional (e.g. many technical controls also require organizational policies, and vice versa).

• New Controls for New Challenges: Within those 93 controls, 11 new controls have been added to cover emerging security domains and technologies These new controls address areas such as Threat Intelligence, Cloud Security, ICT readiness for business continuity, Physical Security Monitoring, Configuration Management, Secure Coding, Data Masking, Data Leakage Prevention, Monitoring Activities, Web Filtering, and Information Deletion For example, a new control on Threat Intelligence (A.5.7) encourages organisations to systematically gather and use cyber threat information, while Information Security for Cloud Services (A.5.23) addresses securing data and processes in the cloud a vital consideration as many enterprises have moved to cloud services. Each new control reflects a current issue that organisations must manage to maintain confidentiality, integrity, and availability of information.

• Refined and Merged Controls: In addition to the 11 new controls, many existing controls were updated or merged. The total count dropped to 93 because several controls were consolidated to eliminate redundancies or outdated concepts. (In fact, 58 controls were updated and 24 were merged in the update) The language of controls has also been clarified for better understanding. For instance, overlapping controls related to cryptography or access control may have been combined into single clearer controls. This refinement means your organisation should review how existing security measures map to the revised control set  some controls you previously implemented might now be covered under a new name or combined with others.

• Practical Impact: Organisations will need to update their Statement of Applicability (SoA) to reflect the new Annex A controls. The SoA is a required document that lists which controls are applicable and how they are implemented or justified if excluded. With the new Annex A, your SoA must be revised to include any of the 11 new controls that apply and to align with the new grouping of controls. For example, if your company relies heavily on cloud services, the new cloud security control will likely be “applicable” and you should document how you’ve implemented it (perhaps via cloud provider due diligence, encryption, etc.). Similarly, controls that were merged or renamed should be cross-checked: ensure nothing fell through the cracks during the transition. Re-evaluate your risk treatment plans against the new control set  the standard explicitly suggests revisiting your risk assessment in light of the updated controls.

Evolving Risk Management Framework: From Periodic to Continuous

ISO 27001 has always been a risk-driven standard identifying and treating information security risks is at its core. The 2022 revision reinforces this by fine-tuning the risk management expectations and integrating them into a more continuous improvement cycle:

• Continuous Risk Monitoring: The updated standard places less emphasis on a static, one-time risk assessment and more on ongoing, “living” risk management. Organizations are expected to continually evaluate and monitor risks, adapting controls as needed, rather than treating risk assessment as an annual checklist exercise. In practice, this means your risk register should be updated regularly (e.g. quarterly or whenever significant changes occur) to reflect new threats or changes in the business, rather than being reviewed only before audits. The revision encourages a dynamic risk analysis process that keeps pace with the fast-changing threat landscape.

• Broader Organisational Involvement: There is a stronger focus on risk management being an organization-wide responsibility, not just an IT task. The new guidance links risks, controls, and responsible roles more explicitly. Clear ownership of risks is now emphasised  management must assign and communicate who is accountable for which risks and controls. For example, a cybersecurity risk related to phishing might be owned by the IT security manager, but the mitigation (employee training control) also involves HR and department heads. The standard’s language (aligned with the Harmonised Structure’s focus on leadership) makes it clear that top management and all departments should be aware of and involved in managing information security risks. This cultural shift means executives and unit leaders should actively participate in risk assessments and treatment decisions, fostering a security mindset beyond the IT department.

• Risk Treatment Clarity: The requirements for risk treatment (ISO 27001 clause 6.1.3) have been made more precise in the new version While the fundamental approach remains  identify risks, evaluate their impacts and likelihood, then decide on treatment (mitigate, transfer, accept, or avoid)  the standard now ensures organisations tie those treatments to the Annex A controls more explicitly. In other words, when you choose how to treat a risk, you should clearly reference which Annex A control(s) you are implementing to do so. This promotes consistency and ensures no important controls are overlooked.

• Addressing Opportunities and Change: Following the unified management system structure, the revised ISO 27001 also prompts organisations to consider not just risks but also opportunities for improvement as part of planning. Additionally, a new clause (Clause 6.3, “Planning of Changes”) was introduced to ensure that any changes to the ISMS are conducted in a planned manner. For instance, if you plan to adopt a new technology or shift a business process, the ISMS should have a procedure to assess the security impact of that change before it happens. This encourages proactive risk management during organisational change, reducing the chance of security gaps when your business evolves.

Structural Revisions Aligned with the Harmonised Structure

The ISO/IEC 27001:2022 standard has been realigned to the ISO Harmonised Structure (HS) (formerly known as the High-Level Structure) that all modern ISO management system standards follow. This structural update brings consistency in clause numbering and titles, making it easier to integrate ISO 27001 with other standards your organization might use (quality, environmental, etc.). Here are the notable structural changes and their implications:

• Clause Reordering and Additions: The overall sections of ISO 27001 remain familiar (Context, Leadership, Planning, Support, Operation, Performance Evaluation, Improvement), but some have new sub-clauses. For example, Clause 6 (Planning) now includes Clause 6.3 “Planning of Changes”, explicitly requiring a process for managing changes to the ISMS(as mentioned above). This was added to mirror the structure in other standards like ISO 9001 and underscores change management in security. Additionally, Clause 5.3 (Organizational roles, responsibilities, and authorities) was updated to ensure that information security roles and responsibilities are not only assigned but also communicated within the organization reinforcing accountability.

• Internal Audit and Management Review: The requirements for internal audits (Clause 9.2) and management reviews (Clause 9.3) have been expanded and detailed in line with the harmonised structure. In ISO 27001:2022, these clauses are subdivided (e.g., 9.2.1 and 9.2.2 for audit; 9.3.1–9.3.3 for review) to provide clearer guidance on inputs and outputs. While the fundamental process (audit your ISMS and have management review its performance) hasn’t changed, the additional sub-clauses ensure a more thorough and standardised approach. Executives and compliance officers should note that management reviews are expected to cover specific topics (e.g., ISMS performance, resource needs, opportunities for improvement) in a structured way. The structural clarity helps make sure nothing is overlooked in keeping the ISMS effective.

• Emphasis on Continual Improvement: The final section (Clause 10) on improvement is adjusted slightly to align with HS, but the core message is the same: organisations must continually improve their ISMS. Clause 10.1 (nonconformities and corrective action) and 10.2 (continual improvement) are re-ordered, emphasising that handling of incidents/nonconformities leads into broader improvement. There are no new substantive requirements here, but the framing serves as a reminder to leadership that information security is not a “set and forget” endeavor. Continual improvement is a perpetual clause  fitting for the evolving nature of security risks.

• Integrated Management Systems: For organisations already certified to multiple ISO standards, the harmonised structure is a welcome change. It means ISO 27001’s clauses align with those of ISO 9001, ISO 14001, etc., making integrated audits and combined management systems more straightforward. You can more easily map common processes (like internal audits, management reviews, document control) across systems. Strategically, this can reduce duplication of effort and ensure that information security considerations are woven into the fabric of overall business processes. For example, a company could synchronize its ISO 27001 management review with its ISO 9001 quality management review meetings, since the structure and some content now parallel each other.

Key Takeaways for Transitioning to ISO 27001:2022

Transitioning to the new standard requires preparation but is very manageable with a proactive approach. Below are key takeaways and practical steps for executives, IT managers, and compliance teams as you prepare for the ISO/IEC 27001:2022 transition (with a transition deadline of October 31, 2025 for existing certifications):

• Start Early and Educate Your Team: First, familiarise yourself and your team with the new standard’s content and changes Obtain the ISO/IEC 27001:2022 standard and/or training materials, and conduct internal workshops or training sessions. Ensure that not only the compliance officers but also IT staff and relevant managers understand what’s new. For instance, brief your IT security team on the new Annex A controls (e.g., what “Secure Coding” or “Threat Intelligence” controls entail) and brief top management on their role in supporting these changes.

• Perform a Gap Analysis: Compare your current ISMS against the revised requirements. Identify gaps that need to be addressed this includes checking each new or changed control in Annex A against your existing controls. Questions to ask: Do we have something in place for each of the 11 new controls? Are any of our current controls or policies outdated relative to the new guidance? Also review clause-by-clause: for example, ensure you have a procedure for “planning changes” to the ISMS (new Clause 6.3) and that top management’s responsibilities (Clause 5) are fully covered. This gap assessment will highlight areas requiring updates.

• Update Risk Assessment and SoA: Treat the revision as an opportunity to refresh your risk assessment with current threat information and business changes. Incorporate considerations for new threats like cloud vulnerabilities or advanced malware, which the new controls address. Then update your Statement of Applicability to include relevant new controls and remove any old control references that no longer exist. For example, if Data Loss Prevention (A.8.12) is a new control pertinent to your organisation (perhaps you deal with sensitive customer data), add it to your SoA and document how you plan to implement it (such as deploying DLP software or processes). This exercise ensures your risk treatment is comprehensive and aligned with the updated standard.

• Implement Required Controls and Improvements: Where gaps are found, plan and implement the necessary measures to meet the new requirements. Some changes might be procedural (e.g., formalising a change management process for the ISMS or updating documentation to assign risk owners), while others could be technical or operational (e.g., introducing a threat intelligence program or new encryption controls if not already in place). Prioritise controls that address high-risk areas for your business. Example: If your gap analysis shows no formal process for secure software development (addressed by the new Secure Coding control A.8.28), you might establish secure coding guidelines and developer training as part of your remediation plan.

• Engage Leadership and Clarify Roles: Use the revision to renew top management engagement. The standard’s changes make it clear that leadership involvement is crucial. Ensure that executive management is not only aware of the ISO 27001:2022 transition but actively supports it, for instance by allocating resources and participating in high-level risk discussions. Update internal documents to reflect any new or changed roles (per Clause 5.3) and communicate these responsibilities clearly across the organisation. A practical step is to have an executive sponsor for the ISMS who will champion the updates and ensure different departments cooperate (since information security now ties into many areas like HR, IT, procurement, etc.).

• Integrate and Streamline: If your organisation has other ISO certifications or frameworks (e.g., ISO 9001, ISO 22301, NIST CSF), look for ways to integrate the ISMS changes into your broader governance structure. Thanks to the harmonised structure, you can align procedures like incident management or document control across systems. This integrated approach can make the transition more efficient and create synergies  for example, combining training sessions for staff on multiple compliance topics, or updating a unified policy manual that addresses requirements of several standards at once.

• Plan the Transition Audit: Coordinate with your certification body well ahead of time. There is a three-year transition window from the publication date (i.e., until end of October 2025), but note that after April 2024, any new certification or recertification audit must be against ISO 27001:2022. Plan to transition during a regular surveillance or recertification audit if possible to minimise extra audits. Ensure all ISMS changes are implemented and internally audited before the external transition audit. This preparation will help avoid any last-minute nonconformities. By transitioning early, you also demonstrate to clients and partners your commitment to staying current with best practices.

The ISO/IEC 27001:2022 revision represents a pivotal update that brings information security management in line with the realities of today’s digital business. By updating Annex A controls, the standard directly addresses modern threats and technologies (from cloud services to cyber threat intelligence). Changes to the risk management framework encourage organisations to be more agile and proactive in assessing risks, with leadership playing an active role in security governance. And through the harmonized structural revisions, ISO 27001 is now more compatible with other management standards, aiding cohesive compliance efforts.

For executives and corporate leaders, the message is clear: information security is now firmly a boardroom issue. Ensuring a smooth transition to ISO 27001:2022 isn’t just about technical compliance it’s about reinforcing stakeholder trust, safeguarding the organisation’s future, and integrating security into the organisation’s strategic DNA. With proper preparation and a commitment to continuous improvement, companies can not only meet the revised standard but leverage it as a framework for stronger, more resilient business operations in the face of evolving cyber risks.

Begin assessing your current security posture against the new requirements and build a transition roadmap. By prioritising these updates, your organisation will be well-prepared for a successful ISO 27001:2022 certification and better equipped to handle the security challenges of the coming years