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After a false start, where the update was put forward as an Amendment rather than a new version, the new ISO27001 2022 has been published by the ISO and is available via their website at the sum of 118 Swiss Francs. It’s been nine years, to the month, since the previous version came out, so what’s new in this edition, and where do we go from here?
It’s fair to say that this update has been driven almost exclusively by two forces; a desire to make the management system requirements match up with the latest Annex SL structure and wording, and the need to align Annex A of the standard with the 2022 version of the ISO27002 guidance.
Let’s take these two factors in turn and explore what’s changed.
ISO27001 was one of the first standards to adopt the Annex SL high level structure back in 2013 and since then the structure has been tweaked a little by ISO with the release of updates to ISO9001 and others from 2015 onwards. But the changes are small and are unlikely to give most certified organizations any sleepless nights.
Firstly, there are some wording changes in the following clauses:
There’s a new sub-clause 6.3 Planning of changes which deals with changes to the management system and requires any changes to be considered from the point of view of their purpose and consequences, the integrity of the ISMS, the resources available, and whether any changes to responsibilities and authorities are involved. This will require a simple planning process to be in place, with evidence that these areas have been considered.
Within Clause 9 (Performance evaluation) sub-clauses 9.2 (Internal audit) and 9.3 (Management review) have been further subdivided into 9.2.1 General, 9.2.2 Internal audit program, 9.3.1 General, 9.3.2 Management review inputs and 9.3.3 Management review results respectively. The two sub-headings in Clause 10 have been swapped around. This is mainly to aid readability and to match the latest definition of Annex SL (also known as the “Harmonized Structure”).
There has already been a lot written about the changes to Annex A, as we have known exactly what will change for some time, since the revision to the ISO27002 guidance document was published in early 2022.
As expected, there are now a total of ninety-three controls, grouped into four themes:
Since the 2013 version had one hundred and fourteen controls, you would think that the number of controls had reduced by twenty-one. But no, the clear statement is that not only are all of the previous controls incorporated into the new set, there are in fact eleven new ones:
Some of these could rightly be seen as clarifications of previous controls (such as Physical security monitoring and Secure coding), some bring in content that was previously within other standards (for example, Information security for use of cloud services, from ISO27017), and some really are new – I don’t remember there being any reference to Threat intelligence in the old control set.
As well as the eleven new ones, there are twenty-four that have been merged, and fifty-eight revised – total ninety-three.
So the 2022 ISO27001 is more “harmonized” and has a shiny new set of Annex A controls. What happens now? Well, if your organization is already certified to the standard then you have three years to move across to the new version. The earliest you will probably be able to do this will be around the end of Q3 2023 as the certification bodies need to get their accreditation first.
If you’re currently working towards certification to the 2013 version, that last date you will be able to do this will be April 2024. The big decision then, will be to decide whether to carry on in that direction, or to move your efforts across to the 2022 version of the standard straight away.
The ISO27001 Toolkit has been updated and is in line with the 2022 standard, available to purchase on our website. We’ve also hosted a webinar ISO27001:2022 – The New Standard. Click the link to watch the recording.
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For more guidance on implementing the ISO27001:2022 standard, we’ve put together a list of our best free resources including video guides, blogs and downloadable documents.