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ISO 27001 Controls: A Guide to Implementing Annex A Controls

ISO 27001 Controls: A Guide to Implementing Annex A Controls

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TL;DR
  • ISO 27001 controls are Annex A safeguards that organizations use to manage information security risks and support their Information Security Management System (ISMS).
  • ISO/IEC 27001:2022 includes 93 Annex A controls grouped into four themes: organizational, people, physical, and technological. The 2013 structure, with 114 controls across 14 domains, has been retired.
  • You do not need to implement every Annex A control. Select controls based on your risk assessment and risk treatment plan, and document applicable controls, exclusions, justifications, and implementation status in the Statement of Applicability (SoA).
  • Clauses 4–10 define the mandatory ISMS requirements for certification, while Annex A controls show how your organization addresses specific risks, assigns ownership, prepares evidence, and remains audit-ready.

ISO 27001 is the international standard for building an Information Security Management System (ISMS). An ISMS is the set of policies, processes, and technical controls you use to manage information security risk. The current version, ISO/IEC 27001:2022, lists 93 controls in Annex A, and you choose the ones that apply to your organization.

This guide walks you through the 93 controls, how they are grouped, how to decide which ones you actually need, and what evidence an auditor expects to see.

Keep in mind: The 2013 version is retired. Organizations had until 31 October 2025 to move from ISO 27001:2013 to ISO 27001:2022. After that date, certificates issued against the 2013 version are no longer valid. If you did not transition in time, you now pursue full recertification against the 2022 version (a Stage 1 and Stage 2 audit), not the lighter transition path that used to exist. Everything below reflects the 2022 structure.

What are ISO 27001 controls?

ISO 27001 controls are the safeguards you implement to manage information security risks and support your ISMS. In ISO/IEC 27001:2022, Annex A references 93 controls grouped into four themes: organizational, people, physical, and technological.

You do not have to implement all 93. You select controls based on your risk assessment and risk treatment plan, then record those decisions in your Statement of Applicability. A good SoA explains which controls apply, which do not, why you made each call, and how the applicable ones are implemented.

“Our 2026 survey found that SOC 2 and ISO 27001 continue to dominate adoption, together accounting for over 85% of certifications selected. “

The Business ROI of Compliance Report

How many ISO 27001 clauses and controls are there?

ISO 27001:2022 has 11 clauses (0–10), of which Clauses 4–10 define the ISMS requirements, supported by 93 Annex A controls. The controls are grouped into four themes: organizational, people, physical, and technological. Not all of them are IT controls. Many cover governance, people, and physical security.

You must meet the requirements in Clauses 4 through 10 to claim compliance. In practice, certification depends on satisfying every requirement across those clauses, while Annex A gives you the menu of controls you draw from to treat your specific risks.

Every organization picks the controls that apply to its risk profile. If a control does not apply, you document the reason in your SoA rather than implementing it for the sake of completeness.

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“Sprinto made the SOC 2 and ISO 27001 compliance process significantly more structured and less overwhelming. The platform automates a lot of evidence collection and continuously monitors controls, which saved us a lot of manual effort.”

ISO 27001:2022 Annex A controls: The four themes

ISO 27001:2022 organizes its 93 controls into four themes, each tied to a different area of ownership. This replaces the 14-domain structure used in the retired 2013 version. Here is what each theme covers and the evidence auditors typically look for.

1. Organizational controls: Annex A.5 (37 controls)

This is the largest theme and the administrative backbone of your ISMS. It covers governance-level measures: information security policies, roles and responsibilities, segregation of duties, supplier and cloud-service security, your access control policy, threat intelligence, and incident management planning. Most cross-functional and policy work lives here.

Evidence to prepare:

  • Documented, management-approved information security policies, communicated to staff and reviewed on a set schedule
  • Defined security roles, responsibilities, and reporting lines
  • Vendor risk assessments and a documented supplier and third-party management policy
  • An access control policy plus proof of periodic access reviews
  • A threat intelligence process and a documented incident response plan

2. People controls: Annex A.6 (8 controls)

This theme covers the human side of security across the full employee lifecycle: screening and background checks, security responsibilities written into employment terms, awareness training, disciplinary processes, remote working, and confidentiality or non-disclosure agreements.

Evidence to prepare:

  • Background verification records for new hires
  • Signed acknowledgment of security policies and signed NDAs
  • Records showing employees complete periodic security awareness training
  • A defined process for securing data when people join, change roles, or leave

3. Physical controls: Annex A.7 (14 controls)

This theme protects your physical premises and equipment. It covers secure areas, physical entry controls, physical security monitoring, protection against environmental and natural threats, clear desk and clear screen, equipment security, and secure disposal of assets and media.

Evidence to prepare:

  • Physical entry controls and monitoring for sensitive areas
  • Endpoints configured to auto-lock after a set period of inactivity
  • Secure media handling and disposal procedures

Effectiveness is subjective but if you want to measure say technical controls, set operational KPIs. Is multi-factor enabled for all accounts? Is traffic encryption enabled? What are the training completion rates and so on? You can use automated tools to get all this information directly from APIs.”

Fabian Weber, vCISO and ISO 27001 auditor

4. Technological controls: Annex A.8 (34 controls)

This is the largest and most technical theme, and where your IT and engineering teams focus. It covers authentication, encryption, malware protection, logging and monitoring, secure coding, configuration management, data masking, data leakage prevention, web filtering, backups, and protection during development and testing.

Evidence to prepare:

  • Encryption of customer data at rest and in transit
  • Malware protection on endpoints that reach production systems
  • Logging, monitoring, and alerting on production assets
  • Vulnerability scans, penetration tests, and a documented backup and disaster recovery process
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That’s a lot of controls to keep track of.

Sprinto keeps evidence for every applicable control current, every day.

What changed in ISO 27001:2022: the 11 new controls

The 2022 update did not just renumber things. It trimmed the count from 114 to 93 by merging overlapping controls, and it added 11 new ones to address risks that barely existed when the 2013 version was written:

  • A.5.7 Threat intelligence
  • A.5.23 Information security for use of cloud services
  • A.5.30 ICT readiness for business continuity
  • A.7.4 Physical security monitoring
  • A.8.9 Configuration management
  • A.8.10 Information deletion
  • A.8.11 Data masking
  • A.8.12 Data leakage prevention
  • A.8.16 Monitoring activities
  • A.8.23 Web filtering
  • A.8.28 Secure coding

If you last looked at the standard before 2022, these additions are where most of your gap analysis effort will go.

The 2024 climate amendment (Amendment 1:2024)

ISO 27001 now requires you to consider climate change as part of your ISMS context. That requirement came from ISO/IEC 27001:2022/Amd 1:2024, published in February 2024, a small but mandatory update that adds two sentences to the standard:

  • Clause 4.1 now requires you to determine whether climate change is a relevant issue for your ISMS.
  • Clause 4.2 adds a note that interested parties, such as customers, regulators, and partners, may have climate-related requirements.

No new Annex A controls came with it. For most teams, the impact is light: you document whether climate change affects your information security (for example, extreme weather threatening a data center, or grid instability affecting uptime), and if it does, you fold it into your risk assessment. Do not over-engineer it. A documented determination that it is not a material risk is enough for many organizations. Auditors began checking for this during surveillance audits starting in mid-2024.

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An audit is not just about producing correct documents. You need to link evidence to the controls being tested to clearly show your policies are functioning as they are meant to do.”
Anil Varma, CISO
Officebeacon ISO 27001 case study
G2-rating
4.8/5 on G2

How to identify which ISO 27001 controls you should implement

Your risk assessment decides which controls you implement, not the Annex A list itself. The list is a menu; your risks tell you what to order. Start with a thorough ISO 27001 risk assessment that surfaces the threats most relevant to your business and informs a treatment plan built around your actual exposure rather than a checklist. From there, prioritize controls based on your specific vulnerabilities, your operating environment, and your compliance goals.

A few practical inputs help: review which assets and data need priority protection, find the gaps a control could close, and factor in the regulations your industry expects. Pull in your IT, compliance, and legal stakeholders early, since they usually spot the high-risk areas first.

Download your ISO 27001
Gap Analysis Template Now

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Sprinto keeps all of your ISO 27001 controls audit-ready

Sprinto maps every applicable Annex A control to a risk, an owner, and daily evidence pulled from your live systems, all tracked in your Statement of Applicability. When a control drifts out of compliance, you’re alerted as it happens, so you reach your audit with proof that’s already current instead of rebuilding it.

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See how Sprinto keeps all 93 controls audit-ready on your own stack.

Frequently asked questions.

ISO 27001:2022 has 93 controls in Annex A, grouped into four themes: Organizational (37), People (8), Physical (14), and Technological (34). The earlier 2013 version had 114 controls across 14 domains, but that version has been retired.

No. You do not have to implement all 93. You select the controls that apply based on your risk assessment, and you justify any exclusions in your Statement of Applicability.

The numbering aligns with ISO 27002, the companion standard that provides implementation guidance for each control. ISO 27002’s clauses 1 to 4 are introductory, so its controls begin at clause 5, and Annex A mirrors that by starting its first theme at A.5.

The SoA defines which of the 93 Annex A controls you will implement and how, and it documents the justification for any controls you exclude. It is one of the most scrutinized documents in a certification or surveillance audit.

ISO 27001:2022, the current version, has 93 Annex A controls in four themes: Organizational (A.5, 37 controls), People (A.6, 8 controls), Physical (A.7, 14 controls), and Technological (A.8, 34 controls). There is no separate “2026 version” of the standard; the current standard is the 2022 edition plus the 2024 climate amendment. The 2013 version’s 14-domain structure (A.5-A.18) has been retired, and certificates issued against it expired after 31 October 2025.

Clauses 4 to 10 define the mandatory requirements for establishing, running, and improving your ISMS. They are the “what” of compliance. Controls (in Annex A) are the specific safeguards you choose to treat identified risks. They are the “how.”

There is no separate Annex A control just for AI agents, but AI tools still affect your control selection. If employees or systems use AI that accesses company data, code, customer records, or production workflows, include them in your asset inventory, access reviews, vendor assessments, logging, and risk treatment plan. Treat an AI agent with API access like any other non-human identity: define its owner, limit its privileges, rotate credentials, monitor activity, and remove access when the use case ends. If your AI use is material or customer-facing, ISO/IEC 42001 can run alongside ISO 27001 for AI-specific governance.

Sometimes, but not automatically. If your organization has no owned office, data center, warehouse, or physical server room, some physical controls may be marked as not applicable in the SoA with a clear justification. But you may still need evidence for endpoint security, device disposal, screen-lock settings, remote-work rules, visitor access to any shared office, or physical controls at a new location. The right answer depends on your scope, assets, people, and where information is actually accessed or stored.

Your infosec officer or team is responsible for implementing controls and ensuring your overall compliance with ISO 27001. But the day-to-day responsibility sits with everyone. Your employees are the first line of defense in most attacks, so control implementation is a shared effort across the company, not a single person’s job.

Gowsika
Author

Gowsika

Gowsika is an avid reader and storyteller who untangles the knotty world of compliance and cybersecurity with a dash of charming wit! While she’s not decoding cryptic compliance jargon, she’s oceanside, melody in ears, pondering life’s big (and small) questions. Your guide through cyber jungles, with a serene soul and a sharp pen!
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