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GRC·6 min read(1,027 words)·Published 2026-10-24

10 Steps to Implement ISO 27001 and Get Certified

A step-by-step ISO/IEC 27001:2022 implementation plan: scope, leadership, risk assessment, Statement of Applicability, Annex A controls, internal audit, management review and the certification audit.

10 core sections·Technical reading pace: ~200 WPM

ISO/IEC 27001 is the international standard for an information security management system (ISMS). Certification tells customers, partners and regulators that security is managed as a system, with leadership accountability, risk-based controls and continual improvement, not as a set of one-off fixes.

The 2022 edition keeps the management system clauses 4 to 10 and restructures Annex A into 93 controls in four themes. The ten steps below take an organisation from a blank page to a certification audit. Check where you stand today with the free GRC Compliance Readiness Assessment.

1. Secure Leadership Commitment

ISO 27001 clause 5 places responsibility for the ISMS on top management. In practice this means an executive sponsor who approves the policy, provides budget and people, assigns roles and attends management reviews.

Present the business case in business terms: customer requirements in tenders, reduced breach impact, fewer security questionnaires and a consistent way to manage risk. Agree a realistic timeline and name an ISMS lead who owns the programme day to day.

2. Define the ISMS Scope

Clause 4.3 requires a documented scope. Decide which business units, locations, products, systems and data are included, and record the interfaces and dependencies with anything outside the scope, such as cloud providers or a parent company.

Start with the scope that matters most to customers, often the core product or service and the people and systems that support it. You can extend the scope at a later surveillance or recertification audit.

3. Understand Context and Interested Parties

Clauses 4.1 and 4.2 ask you to identify internal and external issues that affect security, and the interested parties whose requirements the ISMS must address. The 2024 amendment to ISO 27001 also asks organisations to consider whether climate change is a relevant issue.

  • External issues: regulations such as GDPR or NIS2, threat landscape, market and supplier dependencies.
  • Internal issues: culture, structure, technology, skills and existing processes.
  • Interested parties: customers, regulators, staff, shareholders, suppliers and insurers, with the requirements each one has.

4. Write the Information Security Policy and Objectives

Clause 5.2 requires an information security policy approved by top management, and clause 6.2 requires measurable security objectives with owners, resources and deadlines. Good objectives link to business outcomes, for example "100% of production systems covered by MFA by the end of Q2".

This is also the time to plan the topic-specific policies the ISMS will need. The security policy framework guide covers how to structure them.

5. Run the Risk Assessment

Clause 6.1.2 requires a defined, repeatable risk assessment method: how risks are identified, who owns them, how likelihood and consequence are rated and what level of risk is acceptable. ISO/IEC 27005 gives detailed guidance.

Identify risks to the confidentiality, integrity and availability of information in scope, assign each one a risk owner, rate it and compare it to your acceptance criteria. Our risk assessment walkthrough walks through the method, and the free Cyber Risk Register gives you a working register and heat map.

6. Build the Risk Treatment Plan and Statement of Applicability

For every risk above your acceptance level, choose a treatment: modify the risk with controls, avoid it, share it (for example through insurance or a supplier) or retain it with documented approval from the risk owner.

The Statement of Applicability (SoA) lists all 93 Annex A controls, states whether each is applicable, why, and whether it is implemented. Auditors use it as a map of the whole ISMS, so keep it accurate and linked to the risk treatment plan. Each control is explained in plain language in our ISO 27001 Annex A controls list.

Annex A theme (2022)Number of controlsExamples
Organizational (A.5)37Policies, roles, asset inventory, supplier security, incident management, privacy and PII protection
People (A.6)8Screening, terms of employment, awareness and training, disciplinary process, remote working
Physical (A.7)14Physical perimeters, entry controls, clear desk, equipment security and disposal
Technological (A.8)34Endpoint devices, privileged access, secure authentication, logging, backup, secure development

7. Implement the Annex A Controls

Turn the risk treatment plan into a project plan with owners and dates. Prioritise controls that reduce the largest risks and those that auditors and customers check most often: access control, MFA, logging, backup, vulnerability management, supplier security and incident response.

For each control, decide what evidence will prove it works: a configuration export, a ticket, a review record or a report. Collecting evidence as you go is far easier than reconstructing it before the audit.

8. Train People and Build Awareness

Clauses 7.2 and 7.3 require that people doing security-relevant work are competent and that everyone in scope knows the policy, their contribution and the consequences of not complying. Keep records of training and competence. The security awareness program guide shows how to design a program that changes behaviour, not just one that produces completion certificates.

9. Monitor, Measure and Run an Internal Audit

Clause 9.1 requires you to decide what to measure, how and when, and to evaluate the results. Clause 9.2 requires an internal audit program run by people who are objective and impartial about the area they audit.

Audit every clause and the applicable Annex A controls before the certification audit. Record nonconformities, find the root cause and track corrective actions to closure as clause 10.2 requires.

10. Hold a Management Review and Book the Certification Audit

Analyst Note

Organisations certified to ISO 27001:2013 had until 31 October 2025 to transition to the 2022 edition. New certifications are issued against ISO 27001:2022.

Clause 9.3 requires top management to review the ISMS at planned intervals, covering audit results, risk status, objectives, incidents, feedback and opportunities for improvement. Minute the decisions; the record is audit evidence. Our compliance reporting guide covers how to present this.

Choose an accredited certification body. Stage 1 reviews your documentation and readiness. Stage 2 tests whether the ISMS is implemented and effective. Certificates are valid for three years, with surveillance audits in the intervening years. The audit preparation checklist explains how to prepare evidence.

Frequently Asked Questions

How many controls are in ISO 27001:2022 Annex A?+

93 controls in four themes: Organizational (37), People (8), Physical (14) and Technological (34). Which ones apply is decided by your risk assessment and recorded in the Statement of Applicability.

What are the mandatory parts of ISO 27001?+

Clauses 4 to 10: context, leadership, planning, support, operation, performance evaluation and improvement. Annex A controls are not automatically mandatory, but every exclusion must be justified in the Statement of Applicability.

What happens in a Stage 1 and Stage 2 audit?+

Stage 1 checks that the ISMS documentation and scope are in place and that you are ready. Stage 2 tests whether the ISMS and controls are implemented and working, using interviews, records and samples of evidence.

How long is an ISO 27001 certificate valid?+

Three years, with surveillance audits by the certification body in the years between certification and recertification.

References & Further Reading

GuideGRC
8 Steps to Prepare for a Security Audit (ISO 27001, SOC 2 or Customer Audit)
How to prepare for an ISO 27001, SOC 2 or customer security audit: scope, control mapping, evidence collection, GRC platforms, mock audits, interviews and managing findings.
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GuideGRC
How to Conduct a Cybersecurity Risk Assessment in 7 Steps
A step-by-step method for information security risk assessment aligned with ISO 27005 and NIST SP 800-30: assets, threats, likelihood and impact scoring, risk appetite, treatment and the risk register.
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GuideGRC
How to Build a Security Policy Framework: Policies, Standards and Procedures That People Follow
A practical guide to writing, approving and maintaining information security policies: the policy hierarchy, the core policy set, ownership, review cycles and how to prove people follow them.
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How to Drive Security Compliance Across Every Team: A Control Ownership Playbook
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Cybersecurity News Briefing: November 9, 2026
Today's briefing highlights two key themes: rapid credential abuse in recent infostealer attacks and the push for fully domestic hardware in China. Elastic’s analysis of 27 incidents shows attackers can log in with stolen credentials within an average eight minutes, while Huawei’s new Qingyun HM650 desktop claims entirely Chinese components, though verification is pending. Readers should prioritize reviewing and tightening credential monitoring policies.
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