DISC InfoSec blogISO 27001’s Outdated SoA Rule: Time to Move On

May 04 2025

ISO 27001’s Outdated SoA Rule: Time to Move On

Category: Information Security,ISO 27k — disc7 @ 11:54 am

Current Requirement in ISO 27001
ISO 27001 currently mandates that the SoA must include justifications for both the inclusion and exclusion of each Annex A control. This requirement is often interpreted to mean that organizations must provide individual reasoning for every control listed or omitted.
Guidance from ISO 27005:2022
ISO 27005:2022 clarifies that only controls identified through risk assessment and treatment planning should be included in the SoA. These controls are selected because they help reduce risk to acceptable levels. The guidance explicitly states that no further justification is necessary for their inclusion.
Exclusion Justification Also Redundant
By extension, the only valid reason for excluding a control is that it was not identified as necessary in the risk treatment plan. If a control does not mitigate any identified risk, there is no need for it to appear in the SoA, and thus, no detailed justification is required.
Controls Must Be Risk-Driven
Controls exist to manage or modify risks. Including or excluding them must be directly based on whether they are necessary for risk treatment. Requiring extra justification, separate from the risk assessment, is logically inconsistent with the function of controls within an ISMS.
Recommendation to Remove the Justification Requirement
Given this risk-based logic, the recommendation is to eliminate the need for detailed justifications of inclusions or exclusions in the SoA. This requirement appears to be an error or legacy clause in ISO 27001 that contradicts more recent guidance.
Alignment with ISO 27005 and Future ISO 27003
This position aligns with ISO 27005:2022, which supports a simplified, risk-driven approach to the SoA. It is anticipated that the upcoming ISO 27003 update will reinforce this same guidance, helping to resolve the inconsistency across standards.
Practical Experience Supports the Change
Despite popular belief, individualized justifications are not essential. The author has implemented many ISO 27001-certified ISMSs over the past decade without providing such justifications—and all achieved certification successfully.
Simplified SOA Approach Recommended
The SOA should only list necessary controls derived from the risk assessment, with no additional rationale needed for inclusion or exclusion. Controls not identified as necessary should simply not be listed, and the SOA should remain tightly aligned with the risk treatment plan.

Source: ISO27001 suggested change 13

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