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Across 7 modules • Updated Jul 25, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
ISO/IEC 27001 Management Review

How often should management review happen?

ISO/IEC 27001 requires planned intervals but does not prescribe a universal annual, quarterly, or monthly cadence. Set a cadence that gives top management timely oversight of the scoped ISMS and document it in the management-system schedule.

Material incidents, acquisitions, scope changes, important supplier changes, repeated nonconformities, failed objectives, or major risk changes can justify an additional review or an earlier decision forum even when the next planned review is not due.

  • Define the planned cadence, accountable organizer, required participants, and input cutoff.
  • Set event triggers for extraordinary reviews or interim decisions.
  • Do not claim that ISO/IEC 27001 itself mandates an annual review; that cadence is an organizational choice unless another obligation sets it.
Citations
ISO/IEC 27002:2022 standard page

ISO/IEC 27002:2022 provides control guidance that may help determine whether a control change or failure warrants an interim leadership decision.

ISO/IEC 27001 Risk Acceptance

What does ISO/IEC 27001 require before accepting risk?

Clause 6.1.2 requires the risk-assessment process to establish and maintain risk acceptance criteria. The organization identifies risks associated with loss of confidentiality, integrity, and availability within the ISMS scope, identifies risk owners, analyses consequence and realistic likelihood, determines risk levels, compares the results with its criteria, and prioritizes risks for treatment.

Clause 6.1.3 then requires appropriate treatment options, all necessary controls, comparison with Annex A, a Statement of Applicability, and a treatment plan. The risk owners approve that plan and accept the residual information security risks. The standard does not prescribe one scoring scale, approval form, or universal monetary threshold.

  • Apply the approved acceptance criteria consistently; do not invent a different threshold for a difficult exception.
  • Identify the risk owner in the assessment and obtain that owner's approval of the treatment plan and residual-risk acceptance.
  • Keep legal, regulatory, contractual, and interested-party requirements visible: accepting an information security risk does not waive an external obligation.
  • Decision sequence: assess against the maintained criteria; select and document treatment; determine necessary controls and the residual result; check external obligations; route the plan and residual risk to the identified owner or defined escalation authority; then record the decision and reassessment triggers.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 clauses 6.1.2 and 6.1.3 establish risk-acceptance criteria, risk-owner identification, risk evaluation, treatment planning, and risk-owner approval and residual-risk acceptance.

ISO/IEC 27002:2022 standard page

ISO/IEC 27002:2022 provides control guidance that may support selected treatment controls; it does not replace the risk decision required by ISO/IEC 27001.

ISO/IEC 27001 Risk Acceptance

What should a risk-acceptance record contain?

ISO/IEC 27001 requires documented information about the risk-assessment and risk-treatment processes and their results, but it does not prescribe a risk-acceptance form. The record should let another reviewer understand the scoped risk scenario, affected information or process, confidentiality-integrity-availability impact, criteria used, likelihood and consequence rationale, current controls, chosen treatment, residual-risk result, and owner approval.

Link the accepted residual risk to the risk-treatment plan and the Statement of Applicability where controls are involved. An acceptance entry that conflicts with an SoA implementation status or an overdue treatment needs correction or explicit reconciliation.

  • Record the decision date, approving risk owner, acceptance period if used, assumptions, dependencies, and reassessment triggers.
  • Distinguish inherent or pre-treatment risk from residual risk after the chosen treatment.
  • Retain the risk assessment and treatment process records required by Clauses 6.1.2 and 6.1.3, not only an approval email.
  • Show planned controls separately from implemented controls. If a planned control has not operated, do not count its expected effect in the current residual result without an explicit, supported method that permits that treatment of future action.
Citations
ISO/IEC 27005:2022 standard page

ISO/IEC 27005:2022 provides guidance on managing information security risks and can inform the organization's record design and monitoring approach.

ISO/IEC 27001 Risk Acceptance

Who may accept residual information security risk?

ISO/IEC 27001 assigns approval of the risk-treatment plan and acceptance of residual information security risk to risk owners. Security or compliance teams may coordinate the assessment, challenge the evidence, and administer the register, but they should not approve risk on behalf of an unnamed business owner.

The organization should define authority levels for different risk levels. That governance model is an organizational design choice; the standard's fixed point is that the risk owner is identified and provides the required approval and acceptance. A committee may supply escalation or collective governance, but the record should still show the identified risk owner and the authority used for the decision.

  • Name the risk owner and the authority under which that person accepts the residual risk.
  • Escalate risks above delegated thresholds to the defined governance body without losing the named risk owner.
  • Separate control-owner evidence from the risk owner's acceptance decision.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 clause 6.1.3(f) assigns approval of the treatment plan and acceptance of residual information security risks to risk owners.

ISO/IEC 27001 Risk Acceptance

When must an accepted risk be reassessed?

Clause 8.2 requires information security risk assessments at planned intervals and when significant changes are proposed or occur. Apply that rule to accepted risks rather than treating the approval as permanent.

A significant incident, threat change, control failure, new vulnerability, supplier change, scope change, or changed legal or contractual requirement may invalidate the earlier decision. Whether a change is significant depends on the organization's maintained criteria and the facts; record that assessment rather than treating every change as an automatic new acceptance.

  • Set the next planned review and event-based triggers in the acceptance record.
  • Recalculate the risk with the same maintained criteria unless the criteria themselves have been formally changed.
  • Route changed treatment and residual-risk decisions back to the risk owner and update the SoA where control decisions changed.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 clause 8.2 requires risk assessment at planned intervals and when significant changes are proposed or occur, with documented results.

ISO/IEC 27001 SoA Exclusions

How should teams justify Statement of Applicability exclusions under ISO/IEC 27001?

Start with the risk-treatment process, not the Annex A table. Clause 6.1.3 requires the organization to determine every control necessary for its chosen treatments, compare those controls with Annex A to verify that none were overlooked, and then explain any Annex A exclusions in the Statement of Applicability.

An excluded Annex A control is defensible when the organization can show why that reference control is not necessary in the scoped ISMS. The reason may follow from scope, technology, locations, information handled, interfaces, dependencies, assessed risks, or applicable requirements. Another control may contribute to the explanation, but naming an alternative alone does not show that the Annex A control is unnecessary.

  • State the Annex A control identifier, exclusion rationale, scope facts, risks considered, and any alternative control or dependency relevant to the decision.
  • Check the exclusion against applicable legal, regulatory, contractual, and interested-party requirements before approval.
  • Do not use exclusion to hide a necessary control that is planned but not yet implemented; the SoA can record a necessary control as not implemented.
  • Decision sequence: define scope and applicable requirements; assess risk; select treatment options; determine necessary controls from any source; compare them with Annex A; record inclusion, implementation, and exclusion rationales; obtain the required risk-owner approvals; then review the SoA when its basis changes.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 clause 6.1.3 requires necessary-control determination, comparison with Annex A, and an SoA containing implementation status and justification for excluded Annex A controls.

ISO/IEC 27001 SoA Exclusions

What evidence should support an exclusion?

The exclusion should trace back to the documented ISMS scope, risk-assessment results, selected treatment options, necessary-control determination, and the comparison with Annex A. A short rationale can be sufficient when that chain is clear; a generic 'not applicable' label is not self-explanatory.

Keep evidence proportionate to the decision. For example, an organization that does not operate its own data centre should not automatically exclude every physical control: its scope and supplier interfaces must still show which physical risks and responsibilities remain with the organization and which are handled through the provider. A supplier performing the activity can change the implementation method without making the control unnecessary.

  • Link the SoA entry to the specific risk and scope records that support the conclusion.
  • Record the reviewer, approval date, and trigger that would make the control relevant later.
  • Check that customer-facing and certification claims do not imply coverage broader than the scoped exclusion decision.
  • Example: excluding secure development controls may be supportable when no software development exists in scope and no applicable requirement depends on it. Outsourcing development does not automatically support the same result because supplier selection, agreements, oversight, and delivered-software risk can remain in scope.
Citations
ISO/IEC 27002:2022 standard page

ISO/IEC 27002:2022 explains the intent and implementation context of information security controls, helping reviewers test an exclusion rationale.

ISO/IEC 27005:2022 standard page

ISO/IEC 27005:2022 provides risk-management guidance relevant to the assessment and treatment records supporting applicability decisions.

ISO/IEC 27001 SoA Exclusions

Who approves the SoA and its exclusions?

ISO/IEC 27001 explicitly requires risk-owner approval of the risk-treatment plan and acceptance of residual risks. It does not prescribe a universal job title that signs the SoA. The organization should define SoA approval so control selection, exclusions, treatment decisions, and residual-risk approvals remain consistent.

A practical review includes the ISMS owner, relevant risk owners, and control or service owners; legal, privacy, supplier, resilience, or technical specialists should be involved when their requirements or dependencies affect the rationale. This is governance guidance, not a certification rule that creates a mandatory committee.

  • Name the SoA owner and approver in the documented ISMS process.
  • Keep risk-owner approvals with the treatment and residual-risk records, even when the SoA is approved elsewhere.
  • Escalate conflicts between risk, contract, law, control ownership, and exclusion rationale before publishing the SoA.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 requires risk-owner approval of the treatment plan and acceptance of residual risk but does not prescribe a universal SoA approver title or committee.

ISO/IEC 27001 SoA Exclusions

When should exclusions be reviewed?

Review exclusions when the underlying risk assessment or treatment changes. Clause 8.2 requires reassessment at planned intervals and when significant changes are proposed or occur, so the SoA should not remain frozen while scope, systems, suppliers, threats, contracts, or legal requirements change.

Also review an exclusion when audit evidence, an incident, a failed dependency, or a new service shows that the earlier applicability assumptions were incomplete. The result may be a revised rationale, a newly necessary control, or a changed implementation status.

  • Set a planned review date and specific change triggers for each material exclusion.
  • Update the risk register, treatment plan, SoA, owner, and evidence links together when the decision changes.
  • Retain prior rationale as controlled history without presenting it as the current decision.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 clause 8.2 requires risk assessment at planned intervals and when significant changes are proposed or occur; linked SoA decisions should be reviewed when their basis changes.

ISO/IEC 27001 Surveillance Audits

What is a surveillance audit, and what is it not?

A surveillance audit is performed by the certification body during the certification cycle to assess continuing conformity and maintenance of the certified ISMS. It is external certification activity, not the internal audit required by Clause 9.2 and not a substitute for management review under Clause 9.3.

The organization must keep operating the whole management system between external audits. Passing the original certification audit does not freeze the scope, risk register, SoA, controls, or evidence. Certification concerns conformity of the scoped management system; it is not a guarantee that every system is secure or that no incident will occur.

  • Keep internal audit, management review, monitoring, corrective action, and risk reassessment on their planned schedules regardless of the surveillance date.
  • Use the certification body's audit programme and contract for the exact surveillance scope, timing, sampling, and notification rules.
  • Do not describe an internal readiness review as a certification-body surveillance audit.
  • Keep the three activities distinct: internal audit is the organization's own Clause 9.2 evaluation; surveillance maintains external confidence during the active cycle through selected sampling; a recertification audit supports renewal through a broader end-of-cycle evaluation.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 contains the organization's continuing ISMS requirements, including internal audit, management review, risk reassessment, and corrective action.

ISO/IEC 27006-1:2024 standard page

This source states that certification bodies audit and certify ISMS in accordance with ISO/IEC 27001 and supports the certification-body context for surveillance audits.

ISO/IEC 27001 Surveillance Audits

What should be ready for surveillance sampling?

Prepare the current scope, risk assessment and treatment records, SoA, objective and performance results, internal-audit programme and reports, management-review decisions, prior external-audit actions, nonconformities, corrective actions, and operating samples for selected controls.

Follow the certification body's audit plan for the actual sample and evidence period. Be ready to explain material changes and show both normal operation and how the ISMS responded to incidents, failed controls, missed objectives, supplier changes, or other deviations. The audit may select evidence outside a prepared index when it is relevant to the scope and criteria.

  • Map samples to the certified scope and the current SoA rather than presenting unrelated company-wide evidence.
  • Show the cause, action, and effectiveness review for earlier nonconformities instead of only a closed status.
  • Reconcile certificate wording, internal scope, customer claims, and the live products or services before the audit.
  • Example: after adding a new location, cloud platform, or service inside the claimed boundary, update the scope and dependencies, reassess risk, revise the SoA and operating records as needed, and notify the certification body under the agreed process rather than waiting for the auditor to discover the change.
Citations
ISO/IEC 27001 Surveillance Audits

Who does what during surveillance?

The certification body plans and performs the external audit and makes certification decisions under its scheme. ISO/IEC 27006-1 addresses the competence, consistency, and impartiality of bodies that audit and certify ISMSs.

The organization remains responsible for the ISMS: top management, risk owners, control owners, internal auditors, and corrective-action owners must be able to explain and evidence their own decisions. The external auditor does not assume those roles.

  • Name one audit coordinator, but keep evidence explanations with the people who operate and govern each process.
  • Escalate potential scope or certificate impacts to top management and the certification body through the agreed process.
  • Verify certification and accreditation records independently when customers or suppliers rely on the certificate.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 assigns ISMS responsibilities within the organization, including top-management review and risk-owner treatment approval and residual-risk acceptance.

ISO/IEC 27001 Surveillance Audits

How often do surveillance audits happen?

ISO/IEC 27001 sets the organization's ISMS requirements but does not itself state the surveillance dates for a particular certificate. The certification process is governed by ISO/IEC 17021-1, supplemented for ISMS certification by ISO/IEC 27006-1. Under ISO/IEC 17021-1, surveillance audits occur at least once in each calendar year except a recertification year, and the first surveillance audit after initial certification must be no more than 12 months after the certification decision. Use the certification agreement and audit programme for the actual dates, scope, duration, and remote or on-site arrangements.

Do not wait for the scheduled audit when a material change could affect certified scope or the validity of the claim. Follow the certification arrangement's notification process and update the ISMS records as the change occurs.

  • Record the agreed audit schedule and evidence period from the certification-body plan.
  • Set internal readiness checkpoints early enough to close real corrective actions, not to manufacture records.
  • Track recertification separately from surveillance and preserve the certification body's terminology.
  • A certification cycle is normally three years, but the certificate, certification-body programme, and any scheme-specific rules control the organization's actual renewal timetable.
Citations
ISO/IEC 27001:2022 standard page

ISO/IEC 27001:2022 requires the organization's internal audits and management reviews at planned intervals but does not provide a certificate-specific surveillance calendar.

ISO/IEC 27006-1:2024 standard page

ISO/IEC 27006-1:2024 provides the ISMS-specific certification-body requirements; the organization's certification arrangement supplies its actual audit programme.

ISO/IEC 17021-1:2015 standard page

Official ISO source for certification cycles, surveillance activities, recertification, and the general requirements applying to management-system certification bodies.

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