Key takeaways
- ISO/IEC 27001 follows the Harmonized Structure — formerly known as "Annex SL" — that ISO's Technical Management Board mandates for its management system standards.
- Annex A is the list an ISMS draws from, via the standard's required Statement of Applicability, to select controls that treat the risks identified under Clause 6.
- ISO does not itself certify organizations.
- For a firmware or device maker evaluating whether an existing ISO/IEC 27001 certification covers EU regulatory obligations, the honest answer is: partially, and not as a direct substitute.
ISO/IEC 27001:2022, "Information security, cybersecurity and privacy protection — Information security management systems — Requirements," is the current, certifiable International Standard for an information security management system (ISMS), published 25 October 2022 by ISO/IEC JTC 1/SC 27. It is the third edition, superseding ISO/IEC 27001:2013, which ISO's own catalogue marks as withdrawn the same day the 2022 edition published — a direct transition with no gap between editions. Unlike most of the firmware- and device-specific standards covered elsewhere on this site, ISO/IEC 27001 is a general-purpose, organization-level management system standard: it specifies how an organization runs an information security program (risk assessment, objectives, internal audit, management review), not which technical controls a given product must implement.
Why the clause numbering looks familiar
ISO/IEC 27001 follows the Harmonized Structure — formerly known as "Annex SL" — that ISO's Technical Management Board mandates for its management system standards. Per the governing ISO/TMBG Joint Technical Coordination Group communiqué, this structure "defines the terminology, high-level structure (HLS) and core text to enhance the consistency of ISO's and IEC's portfolio of management system standards," and "does form the basis for harmonization of over 40 individual management system standards." In ISO/IEC 27001:2022 this produces seven requirements clauses:
| Clause | Title |
|---|---|
| 4 | Context of the organization |
| 5 | Leadership |
| 6 | Planning |
| 7 | Support |
| 8 | Operation |
| 9 | Performance evaluation |
| 10 | Improvement |
Because ISO 9001 (quality management) and ISO 14001 (environmental management) use the same clause 4-10 skeleton, an organization already certified to one of those can usually fold ISO/IEC 27001 into an existing integrated management system rather than building a parallel documentation structure.
Annex A: 93 controls, 4 themes — and how it relates to ISO/IEC 27002
Annex A is the list an ISMS draws from, via the standard's required Statement of Applicability, to select controls that treat the risks identified under Clause 6. It states control titles only; the implementation detail lives in the companion standard, ISO/IEC 27002:2022, published roughly eight months earlier (February 2022). ISO's own scope statement for 27002 describes it as providing "a reference set of generic information security controls including implementation guidance," designed for use "within the context of an information security management system (ISMS) based on ISO/IEC 27001."
Per UKAS, the UK's national accreditation body, the 2022 revision reorganized the control set substantially: "Annex A has been aligned with the controls defined in ISO/IEC 27002:2022, which contains 93 controls (11 of which are new) organised in 4 themes," and "in addition to the 11 new controls, 24 have been merged and 58 have been updated." ISO/IEC 27002:2022's own clause numbering lays the 93 controls out across four ranges:
| Theme | Clause range | Controls |
|---|---|---|
| Organizational | 5.1-5.37 | 37 |
| People | 6.1-6.8 | 8 |
| Physical | 7.1-7.14 | 14 |
| Technological | 8.1-8.34 | 34 |
The prior, 2013-based Annex A is widely described — though this guide could not confirm the figure against a directly fetchable ISO, UKAS or BSI page — as having organized 114 controls into 14 clauses, making the 2022 revision a consolidation (fewer, re-themed controls) rather than an expansion. Treat that specific 114/14 comparison as a commonly repeated secondary figure rather than a directly quoted ISO statement.
Certification: accredited bodies, a three-year cycle
ISO does not itself certify organizations. Per UKAS: "certification is the third-party confirmation via audit of an organisation's systems or products, whilst accreditation is independent third-party recognition that an organisation has the competence and impartiality to perform specific technical activities such as certification" — UKAS summarizes its own role as accreditation bodies "check[ing] the checkers." In practice, an organization engages an accredited certification body for a two-stage initial audit; a resulting certificate is typically valid for three years, with surveillance audits in years one and two and a full recertification audit in year three before expiry.
One accreditation-landscape note worth flagging for a guide published in late 2026: the International Accreditation Forum (IAF), long the global body coordinating accreditation recognition, ceased independent operation on 1 January 2026, merging with ILAC into the Global Accreditation Cooperation Incorporated (Global ACI). Anyone citing "IAF guidance" on certification-cycle mechanics going forward should check whether that guidance has been reissued under Global ACI instead.
Where ISO/IEC 27001 does — and doesn't — plug into CRA and NIS2
For a firmware or device maker evaluating whether an existing ISO/IEC 27001 certification covers EU regulatory obligations, the honest answer is: partially, and not as a direct substitute. The Cyber Resilience Act's conformity-presumption mechanism (Article 27) runs through harmonised standards published in the EU Official Journal — a status ISO/IEC 27001 does not independently hold for the CRA — and the CRA's own legal text does not name ISO/IEC 27001. ENISA's own unofficial mapping of CRA requirements to existing standards includes ISO/IEC 27001:2022, but states plainly that it found "no single standard that can, alone, satisfy all requirements listed" in CRA Annex I, and specifically notes that ISO/IEC 27001 "does not cover specific technical measures for defence in depth, encryption at rest, or sandboxing" — gaps that matter for a product-level CRA assessment, since 27001 governs the organization's security program rather than a specific product's technical controls. See our guide to the Cyber Resilience Act for the product-side requirements ISO/IEC 27001 does not cover.
NIS2's operative articles use only generic language — encouraging "the use of European and international standards" without naming ISO/IEC 27001 directly — though a non-binding recital cites "the ISO/IEC 27000 series" illustratively, and ENISA has separately published technical guidance mapping NIS2's risk-management measures to ISO/IEC 27001:2022/27002:2022 while cautioning that the mapping "should not be interpreted as a measure of equivalency." In the UK's energy sector, Ofgem's NIS guidance names ISO 27001 as an example "output-based framework" an operator can map against the NCSC Cyber Assessment Framework — relevant context for an OT audience, though it is sector guidance rather than a certification mandate. Treat any claim that ISO/IEC 27001 certification alone satisfies CRA or NIS2 obligations as unconfirmed until checked against the specific regulator or notified body involved.
A workable starting point
Treat Annex A as a menu, not a checklistThe Statement of Applicability process requires justifying exclusions as well as inclusions — a control isn't "failed" by being scoped out, provided the risk assessment that excluded it is documented. Get ISO/IEC 27002:2022 alongside 27001 before scoping an ISMS, not after. Annex A's 93 control titles alone aren't enough to design an implementation; 27002's Control/Purpose/Guidance text is what the Statement of Applicability actually has to reference. Don't assume ISO/IEC 27001 certification closes CRA or NIS2 gapsENISA's own mapping flags specific technical gaps (defence in depth, encryption at rest, sandboxing) for CRA, and both EU laws stop short of naming 27001 as a recognized conformity mechanism in their binding text. Budget for the three-year cycle, not just the initial auditYear-one and year-two surveillance audits and the year-three recertification audit are part of maintaining certification, not optional follow-ups. Check which accreditation body is authoritative before citing oneWith IAF's 1 January 2026 merger into Global ACI, older guidance referencing "IAF" directly may need to be re-verified against current Global ACI material.
SoftWSP's device and firmware security assessments can help map technical evidence — SBOMs, vulnerability handling records, firmware hardening checks — against the Annex A controls an ISMS Statement of Applicability selects: see Device & Firmware Security.
This guide summarizes publicly available ISO, IEC, UKAS and ENISA catalogue/guidance material; ISO/IEC 27001 and 27002's full operative text are copyrighted and must be purchased from ISO, IEC or a national member body. This guide is not a substitute for the full standards or for compliance/legal advice.
Sources
- ISO/IEC: Information security, cybersecurity and privacy protection — Information security management systems — Requirements, ISO/IEC 27001:2022 (committee catalogue record: edition, publication date, pages, ICS codes, price)
- ISO: ISO/IEC 27001:2013 (withdrawn) — catalogue record showing withdrawal on 2022-10-25 and supersession by ISO/IEC 27001:2022
- UKAS: Transition arrangements for ISO/IEC 27001:2022 (Technical Bulletin) — 93 controls / 4 themes / 11 new, 24 merged, 58 updated
- UKAS: Accreditation vs certification — "accreditation bodies check the checkers"
- ISO/TMBG JTCG Task Force 14 Communiqué, Issue 2019-01 — governing text on the Harmonized Structure / "Annex SL" used across ISO/IEC management system standards
- ISO: ISO/IEC 27002:2022 — Information security, cybersecurity and privacy protection — Information security controls (catalogue record: edition, publication date, scope statement)
- ENISA: Cyber Resilience Act Requirements — Standards Mapping (official ENISA analytical mapping, incl. ISO/IEC 27001:2022 gap note)
- ENISA: Technical implementation guidance on cybersecurity risk management measures (NIS2), v1.0 — mapping to ISO/IEC 27001:2022/27002:2022 with non-equivalency caveat
- Ofgem: NIS Guidance for Downstream Gas and Electricity Operators of Essential Services in GB v2.0 — cites ISO 27001 as an example output-based framework mapped to the NCSC CAF
Frequently asked questions
What is ISO/IEC 27001:2022, and who publishes it?
ISO/IEC 27001:2022, "Information security, cybersecurity and privacy protection — Information security management systems — Requirements," is the third edition of ISO/IEC's certifiable standard for an information security management system (ISMS), published 25 October 2022 by ISO/IEC JTC 1/SC 27 and carrying ICS codes 35.030 and 03.100.70. It superseded the second edition, ISO/IEC 27001:2013, which ISO's own catalogue marks as withdrawn on the same date — 2022-10-25 — alongside that edition's two corrigenda. ISO's committee page lists the current edition at 19 pages and CHF 155 through the ISO and IEC webstores; ISO/IEC 27001 is copyrighted and must be purchased from ISO, a national member body (e.g. BSI in the UK, ANSI in the US) or an authorized reseller — no free full-text mirror is authorized, so this guide summarizes publicly available catalogue and committee information rather than quoting the standard's operative text at length. ISO/IEC 27001:2022 also has one published amendment, Amendment 1:2024 ("climate action changes"), per ISO's own catalogue — a change applied across ISO's management-system-standard portfolio from 2024, not specific to information security.
What is the clause 4-10 structure, and why do other ISO management standards look the same?
ISO/IEC 27001 follows the Harmonized Structure (formerly called "Annex SL") that ISO's own Technical Management Board Joint Technical Coordination Group mandates for all ISO/IEC management system standards, to keep their core clause numbering and terminology consistent. Per the governing ISO/TMBG communiqué, this structure "defines the terminology, high-level structure (HLS) and core text to enhance the consistency of ISO's and IEC's portfolio of management system standards" and "does form the basis for harmonization of over 40 individual management system standards." In ISO/IEC 27001:2022 this yields seven requirements clauses: 4 Context of the organization, 5 Leadership, 6 Planning, 7 Support, 8 Operation, 9 Performance evaluation, and 10 Improvement — the same clause skeleton used by ISO 9001 (quality) and ISO 14001 (environmental management), which is why an organization already certified to one can typically integrate a second ISO management system without rebuilding its documentation structure from scratch.
What is Annex A, and how many controls does it list?
Annex A lists the controls an ISMS can select from (via the standard's Statement of Applicability process) to treat identified risks; it does not describe each control in implementation detail — that full guidance lives in the companion standard ISO/IEC 27002:2022. Per UKAS (the UK's national accreditation body), ISO/IEC 27001:2022's "Annex A has been aligned with the controls defined in ISO/IEC 27002:2022, which contains 93 controls (11 of which are new) organised in 4 themes," and notes that "in addition to the 11 new controls, 24 have been merged and 58 have been updated" relative to the prior control set. ISO/IEC 27002:2022's own clause numbering lays out those 93 controls across four ranges: 5.1-5.37 (Organizational controls, 37), 6.1-6.8 (People controls, 8), 7.1-7.14 (Physical controls, 14) and 8.1-8.34 (Technological controls, 34). The prior, 2013-based control set is widely reported (though not confirmed against a fetchable ISO/UKAS/BSI page in this guide's research) as having organized 114 controls into 14 clauses — treat that specific comparison as a commonly cited secondary figure rather than a directly quoted ISO statement.
How does ISO/IEC 27001:2022 relate to ISO/IEC 27002:2022, and how does certification work?
ISO/IEC 27002:2022 ("Information security, cybersecurity and privacy protection — Information security controls") was published first, in February 2022, roughly eight months ahead of ISO/IEC 27001:2022 in October 2022. ISO's own scope statement for 27002 says it "provides a reference set of generic information security controls including implementation guidance" designed for use "within the context of an information security management system (ISMS) based on ISO/IEC 27001" — in practice, 27001's Annex A gives only the control titles grouped by theme, while 27002 carries the full Control/Purpose/Guidance text an organization implements against. Certification itself is performed by accredited, independent certification bodies rather than by ISO: per the UK Accreditation Service (UKAS), "certification is the third-party confirmation via audit of an organisation's systems or products, whilst accreditation is independent third-party recognition that an organisation has the competence and impartiality to perform specific technical activities such as certification" — summarized as accreditation bodies "check the checkers." The typical cycle, reflected in accreditation-body guidance, is a two-stage initial audit, a certificate valid for three years, surveillance audits in years one and two, and a recertification audit in year three. Note for anyone tracking the accreditation landscape as of this guide's 2026 publication: the International Accreditation Forum (IAF) ceased independent operation on 1 January 2026, merging with ILAC into the Global Accreditation Cooperation Incorporated (Global ACI) — current certification-cycle guidance should be checked against Global ACI rather than the now-archival IAF.
Does the EU Cyber Resilience Act or NIS2 recognize ISO/IEC 27001 certification directly?
Not as a named, binding mechanism in either law's own operative text, based on this guide's research. The Cyber Resilience Act's conformity-presumption mechanism (Article 27) runs through harmonised standards published in the EU Official Journal, which have not been adopted for the CRA as of this guide's research, and the CRA's own text does not name ISO/IEC 27001. ENISA has published an unofficial analytical mapping of CRA requirements against existing standards that includes ISO/IEC 27001:2022, but explicitly cautions that it found "no single standard that can, alone, satisfy all requirements listed" in the CRA's Annex I, flagging for ISO/IEC 27001 specifically that it "does not cover specific technical measures for defence in depth, encryption at rest, or sandboxing." NIS2's operative articles (e.g. Article 21) use only generic language encouraging "the use of European and international standards," without naming ISO/IEC 27001; a non-binding recital (Recital 79) does cite "European and international standards, such as those included in the ISO/IEC 27000 series" as illustrative. ENISA has separately published technical implementation guidance mapping NIS2's risk-management measures to ISO/IEC 27001:2022 and 27002:2022, while stating the mapping "should not be interpreted as a measure of equivalency." In the UK, energy-sector guidance from Ofgem (the NIS Regulations competent authority for that sector) names ISO 27001 as an example "output-based framework" operators may map against the NCSC Cyber Assessment Framework — useful context for an OT/energy audience, though it is sector guidance, not a certification mandate. Treat any claim that ISO/IEC 27001 certification alone satisfies CRA or NIS2 obligations as unconfirmed, and verify against the specific regulator or notified body involved.
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