FAQGlobalISO/IEC 27001

ISO/IEC 27001 FAQ SoA Exclusions

How should teams justify exclusions under ISO/IEC 27001?

The SoA must justify every . A that is not yet implemented is not an exclusion, and Clauses 4-10 cannot be excluded from a conformity claim.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

The records which controls are necessary, why they are included, whether they are implemented, and why any Annex A controls are excluded. An exclusion is the organization's justified conclusion that an Annex A reference control is not necessary for its scoped ISMS. The organization must first determine all controls needed for its chosen risk treatments and compare them with Annex A so none are overlooked. A may be recorded as not implemented; it cannot be relabelled as excluded. Clauses 4-10 cannot be excluded when claiming conformity.

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5 of 5 questions
Question 1

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 .

An 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 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.
Question 2

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.
Question 3

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.
Question 4

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 , or a changed .

  • 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.
Question 5

Questions and answers

What makes an Annex A exclusion acceptable in the ?

The SoA should include the justification for excluding any Annex A controls, together with the scope and risk-treatment context that led to the decision. ISO/IEC 27001:2022 clause 6.1.3 requires the to contain the justification for excluding Annex A controls.

Can an organization exclude ISO/IEC 27001 clauses 4 to 10 from its ISMS?

No. ISO/IEC 27001:2022 clause 1 says excluding any of the requirements specified in Clauses 4 to 10 is not acceptable when an organization claims conformity to the standard.

How often should SoA exclusions be reviewed?

Review them at planned intervals and whenever significant changes are proposed or occur. ISO/IEC 27001:2022 clause 8.2 requires information security risk assessments at planned intervals or when significant changes are proposed or occur, and the SoA should be updated when the risk picture changes.

What evidence should support a SoA exclusion decision?

At minimum, link the rationale to the ISMS scope, risk-assessment results, chosen treatment, necessary-control determination, and Annex A comparison. Add applicable legal, contractual, supplier, technical, audit, or change evidence when it affects the decision. The standard does not prescribe one exclusion form, but a bare 'not applicable' label does not explain the required justification.

Can a necessary Annex A control be excluded because it is not yet implemented?

No. If the organization determines that a control is necessary, the must include it and state whether it is implemented. A planned, partial, ineffective, or overdue control remains necessary. Track the gap through the risk-treatment plan, corrective-action process, or other controlled record instead of changing its applicability.

Can an Annex A control be excluded because a supplier performs it?

Not for that reason alone. Clause 4.3 requires the ISMS scope to consider interfaces and dependencies with other organizations, and Clause 8.1 requires relevant externally provided processes, products, and services to be controlled. Determine whether the control remains necessary, record the supplier and internal responsibilities, and show the contract, assurance, monitoring, and response evidence. Supplier delivery can change how a control is implemented without making it unnecessary.

Primary sources

References and citations

iso.org5 citations
Referenced sections
  • This source supports control implementation guidance and control-implementation expectations supporting ISO/IEC 27001 governance.
  • ISO/IEC 27002:2022 provides guidance for the Annex A reference controls and can help assess their purpose and implementation context.
  • ISO/IEC 27002:2022 explains the intent and implementation context of information security controls, helping reviewers test an exclusion rationale.
Show 2 more
  • ISO/IEC 27002:2022 may inform specialist review of control applicability without creating a mandatory approval body.
  • ISO/IEC 27002:2022 provides control guidance relevant when changed circumstances alter an applicability decision.
"Information security controls"
iso.org4 citations
Referenced sections
  • ISO public listing for the ISMS requirements standard. Applicability requirements summarized here come from ISO/IEC 27001:2022 clauses 1, 6.1.3 and 8.2; the public listing does not reproduce those clauses.
  • 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 27001:2022 requires risk-owner approval of the treatment plan and acceptance of residual risk but does not prescribe a universal SoA approver title or committee.
Show 1 more
  • 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.
"Information security management systems - Requirements"
iso.org2 citations
Referenced sections
  • This source supports risk treatment and monitoring context that informs control decisions and residual risk handling.
  • ISO/IEC 27005:2022 provides risk-management guidance relevant to the assessment and treatment records supporting applicability decisions.
"Guidance on managing information security risks"
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