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ISO 27001:2022 Compliance

ISO 27001:2022
Readiness Checklist

A comprehensive, enterprise-grade checklist to help your organisation assess readiness for ISO 27001:2022 certification. Covers all mandatory clauses, Annex A controls, gap assessment, and the full certification journey. Built from 700+ enterprise engagements across India and the Middle East.

93
Annex A Controls
7
Mandatory Clauses
4
Control Themes

Overview

What is ISO 27001:2022?

About the Standard

ISO/IEC 27001:2022 is the international standard for Information Security Management Systems (ISMS). It provides a systematic framework for managing sensitive company information, ensuring confidentiality, integrity, and availability. The 2022 revision replaced the 2013 edition with significant restructuring of Annex A controls.

For Indian enterprises, ISO 27001 certification is increasingly a prerequisite for doing business with global clients, meeting regulatory expectations from RBI, SEBI, IRDAI, and CERT-In, and demonstrating security maturity to stakeholders.

Key Changes from 2013 to 2022

  • Annex A restructured from 14 domains to 4 themes: Organisational, People, Physical, and Technological
  • Controls reduced from 114 to 93 controls — merged, updated, and streamlined
  • 11 new controls added: threat intelligence, cloud security, data leakage prevention, monitoring, web filtering, secure coding, configuration management, and more
  • Control attributes introduced: control type, security property, cybersecurity concept, operational capability, and security domain
  • Transition deadline for existing certifications: 31 October 2025

Mandatory Requirements

Clauses 4–10 Checklist

These clauses define the mandatory management system requirements. Every item must be addressed for certification.

4

Clause 4: Context of the Organisation

Understand the organisation and its context to define the ISMS scope.

  • Identify internal issues relevant to information security (culture, structure, capabilities, technology)
  • Identify external issues (regulatory, legal, competitive, market, geopolitical environment)
  • Identify interested parties and their requirements (clients, regulators, partners, employees)
  • Determine legal, regulatory, and contractual obligations (IT Act 2000, DPDP Act, RBI/SEBI/IRDAI directives)
  • Define the scope of the ISMS — organisational units, locations, assets, and technologies
  • Document ISMS boundaries and applicability, including interfaces and dependencies
  • Establish the ISMS considering internal/external issues and interested party requirements
  • Document processes needed for the ISMS and their interactions
5

Clause 5: Leadership

Ensure top management commitment and governance structure.

  • Obtain formal top management commitment to the ISMS (board resolution or management directive)
  • Establish an information security policy aligned with business objectives
  • Ensure the policy is communicated, available, and understood across the organisation
  • Define and assign ISMS roles, responsibilities, and authorities (CISO, ISO, risk owners)
  • Ensure management reviews are planned and conducted at defined intervals
  • Allocate adequate resources (budget, personnel, tools) for ISMS implementation and maintenance
  • Promote continual improvement as an organisational objective
  • Integrate ISMS requirements into the organisation's existing business processes
6

Clause 6: Planning

Address risks and opportunities, and plan for achieving ISMS objectives.

  • Determine risks and opportunities considering Clause 4 context (internal/external issues)
  • Define and document the risk assessment methodology (criteria, likelihood, impact scales)
  • Conduct a comprehensive information security risk assessment
  • Develop a risk treatment plan with selected controls and justifications
  • Prepare the Statement of Applicability (SoA) — map all Annex A controls with inclusion/exclusion rationale
  • Set measurable information security objectives at relevant functions and levels
  • Plan actions to achieve objectives — what, who, when, resources, and evaluation method
  • Plan for changes to the ISMS ensuring controlled and documented transitions
7

Clause 7: Support

Ensure adequate resources, competence, and documented information.

  • Determine and provide resources needed for ISMS establishment and maintenance
  • Determine required competencies for personnel performing ISMS work
  • Ensure competence through education, training, or experience — maintain evidence of competence
  • Conduct information security awareness programs for all employees and contractors
  • Define internal and external communication processes — what, when, to whom, how
  • Establish documented information requirements for the ISMS
  • Implement document control — creation, updates, version control, approvals
  • Define retention, disposal, and access control policies for documented information
  • Maintain records of training, competency assessments, and awareness activities
8

Clause 8: Operation

Implement and control the processes needed to meet ISMS requirements.

  • Plan, implement, and control processes needed to meet ISMS requirements
  • Implement the risk treatment plan as defined in Clause 6
  • Conduct risk assessments at planned intervals or upon significant changes
  • Ensure outsourced processes are identified, controlled, and monitored
  • Document operational procedures and maintain operational evidence
  • Manage changes to the ISMS operations in a planned and controlled manner
  • Implement controls to mitigate identified risks per the SoA
  • Maintain records of risk assessment results and risk treatment decisions
9

Clause 9: Performance Evaluation

Monitor, measure, analyze, and evaluate the ISMS performance.

  • Determine what needs to be monitored and measured — including security objectives and controls
  • Define methods for monitoring, measurement, analysis, and evaluation
  • Establish when monitoring and measuring shall be performed and by whom
  • Conduct internal audits at planned intervals — ensure auditor independence
  • Develop an internal audit program (scope, frequency, methods, reporting)
  • Conduct management reviews at planned intervals with required inputs
  • Document management review outputs — decisions, improvement opportunities, resource needs
  • Evaluate the performance of information security controls and processes
  • Monitor security metrics and KPIs (incident response times, vulnerability remediation, etc.)
10

Clause 10: Improvement

Drive continual improvement of the ISMS suitability, adequacy, and effectiveness.

  • Establish a process for managing nonconformities and corrective actions
  • React to nonconformities — take action to control and correct; deal with consequences
  • Evaluate the need for action to eliminate the causes of nonconformity
  • Implement required corrective actions and review their effectiveness
  • Make changes to the ISMS based on corrective action results, if necessary
  • Continually improve the suitability, adequacy, and effectiveness of the ISMS
  • Document all nonconformities, corrective actions, and their results
  • Use findings from audits, reviews, and incidents to drive improvement initiatives

Reference Controls

Annex A Control Groups

ISO 27001:2022 restructured Annex A into four themes with 93 controls. Below are key controls from each group that most organisations must address.

A.5 Organisational Controls

Control Name Checklist Item
A.5.1 Policies for information security Define, approve, publish, and communicate a set of information security policies
A.5.2 Information security roles Assign and communicate information security roles and responsibilities
A.5.3 Segregation of duties Ensure conflicting duties and responsibilities are segregated
A.5.4 Management responsibilities Ensure management enforces security policies among employees and contractors
A.5.7 Threat intelligence Collect, analyze, and act on information security threat intelligence
A.5.23 Cloud service security Define and manage information security requirements for cloud services (new in 2022)
A.5.29 ICT readiness for continuity Plan and prepare ICT to ensure business continuity (new in 2022)

A.6 People Controls

Control Name Checklist Item
A.6.1 Screening Conduct background verification checks on candidates prior to employment
A.6.2 Terms of employment Include information security responsibilities in employment contracts
A.6.3 Awareness & training Provide regular information security awareness education and training
A.6.5 Termination responsibilities Define and enforce responsibilities on termination or change of employment
A.6.7 Remote working Implement security measures for remote working arrangements (new in 2022)

A.7 Physical Controls

Control Name Checklist Item
A.7.1 Physical security perimeters Define physical security perimeters and secure areas (data centers, offices, archives)
A.7.2 Physical entry Control physical access with entry controls — badge systems, biometrics, visitor logs
A.7.4 Physical security monitoring Monitor premises continuously for unauthorized access (new in 2022)
A.7.8 Equipment siting Site and protect equipment to reduce environmental threats and unauthorized access
A.7.10 Storage media Manage storage media through lifecycle — use, transport, and disposal

A.8 Technological Controls

Control Name Checklist Item
A.8.1 User endpoint devices Secure information stored on, processed by, or accessible via user endpoint devices
A.8.2 Privileged access rights Restrict and manage the allocation and use of privileged access rights
A.8.5 Secure authentication Implement secure authentication mechanisms (MFA, password policies, SSO)
A.8.8 Vulnerability management Identify, evaluate, and remediate technical vulnerabilities in a timely manner
A.8.9 Configuration management Establish and maintain secure configurations for hardware, software, and networks (new in 2022)
A.8.12 Data leakage prevention Apply data leakage prevention measures to systems and networks (new in 2022)
A.8.16 Monitoring activities Monitor networks, systems, and applications for anomalous behaviour (new in 2022)
A.8.23 Web filtering Manage access to external websites to reduce exposure to malicious content (new in 2022)
A.8.24 Use of cryptography Define and implement rules for cryptography including key management
A.8.25 Secure development lifecycle Establish rules for secure development of software and systems (new in 2022)
A.8.28 Secure coding Apply secure coding principles to software development (new in 2022)

Assessment Template

Gap Assessment Tracker

Use this template to document gaps between your current state and ISO 27001:2022 requirements. Print this page to use as a working document.

Control Area Current State Gap Description Priority Owner Target Date
Information Security Policy ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Risk Assessment & Treatment ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Asset Management ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Access Control ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Cryptography ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Physical Security ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Operations Security ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Communications Security ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
System Acquisition & Development ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Supplier Relationships ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Incident Management ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Business Continuity ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L
Compliance & Legal ☐ None ☐ Partial ☐ Full
☐ H ☐ M ☐ L

Certification Journey

Typical 6–10 Month Timeline

ISO 27001 certification is a structured process. Below is a typical timeline for a mid-size organisation, from initial assessment to certification.

Phase 1

Gap Assessment

Weeks 1–4

Evaluate current security posture against ISO 27001:2022 requirements. Identify gaps, prioritize remediation efforts, and build a project plan.

Phase 2

Remediation

Weeks 5–16

Implement missing controls, update policies and procedures, deploy technical measures, and train staff on new processes.

Phase 3

Documentation

Weeks 12–20

Formalize ISMS documentation — policies, procedures, SOPs, risk register, SoA, and evidence collection.

Phase 4

Internal Audit

Weeks 20–24

Conduct a full internal audit against ISO 27001:2022 requirements. Identify nonconformities and close them before the certification audit.

Phase 5

Stage 1 Audit

Weeks 24–28

Certification body reviews documentation readiness — ISMS scope, policies, risk assessment, SoA, and management review records.

Phase 6

Stage 2 Audit

Weeks 28–36

On-site audit evaluating the effectiveness of the ISMS implementation. Auditors verify controls are operational and effective.

Phase 7

Certification

Weeks 36–40

Receive ISO 27001:2022 certificate upon successful completion. Plan surveillance audits (annual) and recertification (3-year cycle).

Need help with ISO 27001 certification?

Security Brigade has guided 700+ organisations through compliance and certification processes. Our team of CERT-In empanelled experts can help you at any stage of your ISO 27001 journey.