ISO Publishes ISO/IEC 27002:2022 with Modernized Security Controls

Executive briefing: The formal publication of ISO/IEC 27002:2022 on 15 February 2022 triggered immediate planning activity among certification bodies, accreditation authorities, and enterprises preparing for ISO/IEC 27001 transition audits. Although the management-system standard is published separately, Annex A references 27002 controls. Organizations now have to coordinate with certification partners to understand migration timelines, recalibrate assurance testing, and communicate the impact to regulators and customers that rely on ISO certification as a third-party assurance mechanism.

Publication implications

ISO and IEC’s Joint Technical Committee 1, Subcommittee 27 (JTC 1/SC 27) spent five years restructuring ISO/IEC 27002. The release consolidates the control catalogue, introduces control attributes, and includes annexes that map the 2022 controls to the 2013 edition. Accreditation bodies such as the United Kingdom Accreditation Service (UKAS), ANSI National Accreditation Board (ANAB), and Japan Accreditation Board (JAB) now must issue transition guidance to certification bodies outlining how existing ISO/IEC 27001 certificates will adapt once Annex A references change. Organizations planning surveillance audits during 2022 should expect pre-audit questionnaires testing readiness for the updated controls, even before ISO/IEC 27001:2022 is officially released.

The publication also affects regulators and customers who embed ISO/IEC 27001 requirements into licensing or contractual obligations. Financial supervisors (e.g., Singapore MAS, Bank of England Prudential Regulation Authority), health authorities, and cloud service buyers must interpret how quickly suppliers should align with the new control structure. Early communication reduces confusion when due diligence teams review evidence packages still structured around the 2013 edition.

Operational transition steps

Operational leaders should set up cross-functional programmes to handle the transition:

• Establish a transition office: Create a dedicated programme reporting to the CISO or risk officer, including representatives from compliance, operations, IT, HR, and procurement. Assign workstreams to control remapping, tooling updates, training, supplier management, and audit coordination.
• Review certification contracts: Understand obligations within contracts with certification bodies, including notification timelines, pre-audit readiness assessments, and fees for transition audits. Capture expected milestones (e.g., 6-month planning, 12-month implementation, 24-month completion).
• Gap assessment: Conduct a line-by-line comparison using Annex B of ISO/IEC 27002:2022, which maps old controls to the new structure. Document where multiple legacy controls converge (e.g., access management) and where new controls require fresh implementation (e.g., cloud services, threat intelligence).
• Training and awareness: Deliver targeted training for control owners, explaining new control objectives, attribute taxonomy, and evidence expectations. Provide cheat sheets for help desk, DevOps, and facilities teams whose procedures cite control numbers.
• Update risk treatment plans: The Statement of Applicability (SoA) must reference the new control identifiers. Update SoAs, risk assessments, and treatment plans to demonstrate how risks remain mitigated under the new structure.

Governance alignment

Governance committees and boards need assurance that the transition is managed effectively:

• Timeline oversight: Present the transition roadmap to audit and risk committees, including dependencies on ISO/IEC 27001:2022 publication and accreditation body guidance. Establish clear checkpoints for gap closure, control testing, and evidence collection.
• Policy revision: Update policy hierarchies to match revised control categories. Ensure policy owners maintain historical references for jurisdictions still citing ISO/IEC 27002:2013 in legal or regulatory frameworks.
• Budget approvals: Determine funding needs for tooling enhancements, external consultancy, or additional audit support. Boards should understand how the revised control set intersects with digital transformation, zero-trust investments, and resilience programmes.
• Integrated assurance: Align internal audit, risk management, and compliance teams on testing schedules. Encourage internal audit to pilot the new control structure in 2022 engagements to build familiarity before external transition audits.
• Stakeholder communication: Prepare external-facing statements explaining the transition plan to customers, regulators, and partners. Provide timelines for when updated certificates and SoAs will be available.

Technology, data, and automation

Technology teams must evaluate system support for the new control catalogue:

• GRC platform updates: Modify control libraries, workflows, and automated evidence collection tasks to reference the 2022 control numbering. Ensure risk and compliance dashboards can filter controls using attribute values supplied in Annex A.
• Automation scripts: Update infrastructure-as-code templates, security configuration baselines, and CI/CD guardrails to reflect new control objectives. For example, integrate threat intelligence feeds and DLP coverage metrics into continuous compliance monitoring.
• Data classification and masking: Expand data discovery and masking solutions to cover systems in scope for new controls 8.10 and 8.11. Document data lineage and retention logic to satisfy cross-cutting privacy and regulatory obligations.
• Monitoring and response: Enhance logging pipelines, behavioural analytics, and SOAR playbooks aligned with 8.16 Monitoring activities and 8.25 Network security. Validate alert thresholds and integrate with incident-management tooling referenced in business continuity controls.
• Cloud and SaaS governance: Revisit shared responsibility models for SaaS, PaaS, and IaaS environments to prove compliance with 5.23 Information security for use of cloud services. Expand API-based monitoring and contract clauses to secure administrative interfaces.

Sourcing, vendor, and auditor coordination

The updated standard reverberates across the supply chain:

• Third-party attestations: Request updated certification transition plans from managed service providers, data centre operators, and cloud vendors. Ensure they share timelines for aligning their SoAs and certificate renewals.
• Procurement templates: Amend RFPs, contract schedules, and vendor onboarding questionnaires to reference ISO/IEC 27002:2022 controls. Highlight requirements for threat intelligence sharing, configuration management, and data leakage prevention.
• Audit partner engagement: Coordinate with external auditors to align testing procedures, sampling techniques, and evidence requirements. Confirm whether interim assessments are required before the next certification cycle.
• Insurance and liability considerations: Update cyber insurance disclosures to reflect how the organization is addressing new control expectations. Demonstrate to underwriters that transition activities are underway to maintain coverage.
• Consortium collaboration: Engage industry forums (e.g., Cloud Security Alliance, Shared Assessments Program, Information Security Forum) to share transition playbooks and accelerate interpretation of ambiguous control guidance.

Readiness milestones

Establish measurable milestones to track progress:

1. Month 1: Complete gap analysis, establish governance structure, and communicate publication impact to stakeholders.
2. Month 3: Update policy sets, SoAs, and risk assessments; launch targeted training for control owners.
3. Month 6: Implement tooling and process changes for new controls, collect preliminary evidence, and align internal audit testing.
4. Month 9: Conduct mock assessments with certification partners or third-party consultants to validate readiness.
5. Month 12: Finalize documentation, update customer assurances, and schedule formal transition audits.

Strategic outlook

The publication underscores ISO/IEC’s intent to maintain relevance amid rapid shifts in cloud computing, supply-chain threats, and resilience expectations. Organizations that treat the 2022 edition as an opportunity to modernize governance—rather than a compliance checkbox—can harmonize global regulatory obligations, automate evidence collection, and provide boards with clearer risk insights. Early investment in planning and communication will reduce the disruption when accreditation bodies formalize transition deadlines after ISO/IEC 27001:2022’s release.

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