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Statement of Applicability (SoA) for ISO 27001

The Statement of Applicability connects necessary security controls to their justification and implementation status. It does not replace the risk register or treatment plan.

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A Statement of Applicability explains which security controls are necessary for your ISMS and the reasoning behind the selection. It should connect to the scope and risk treatment. Copying a spreadsheet and marking every row “yes” does not explain why controls are needed or what has actually been implemented.

Use Annex A as a comparison

ISO/IEC 27001:2022 contains 93 Annex A controls in four themes, as described in UKAS’s transition bulletin. Start with controls needed for your risks and other applicable requirements, then compare them with Annex A to check for omissions. A control number in a spreadsheet is not evidence that the control operates effectively.

Four records with different purposes

RecordQuestion answered
Risk registerWhat could go wrong and how do we assess it?
Treatment planWhat change will be made, by whom and when?
SoAWhich controls are necessary, why and with what status?
Evidence registerWhat demonstrates implementation and verification?

One system can support all four functions. Keep the meaning of its fields clear, however. Completing a project task should not automatically label a control as continuously effective. Record how evidence relates to the period and service being assessed.

Fictional example: supplier access

A fictional supplier receives temporary access to a customer environment. The risk concerns excessive permissions or access remaining active for too long. The SoA points to the selected access controls and their justification. The treatment plan assigns work to enforce end dates. Approvals, configuration records and a review of expired accounts provide evidence. Until the change is tested, its implementation status should show that limitation.

Explain both inclusion and exclusion

Difficulty is not a substantive reason to exclude a control. Explain the connection with scope, risks and applicable requirements. Inclusion also needs reasoning: what does the control protect, and how is it implemented? An outsourced activity may still require agreements, oversight and checks. “The supplier does it” is therefore not a complete justification. Record your own responsibility and what evidence supports reliance on that supplier.

A practical review before assessment

  1. Trace an important risk through its control to supporting evidence.
  2. Check an exclusion against the actual scope and dependencies.
  3. Compare an implementation status with current operation.
  4. Identify the approved version and who reviews changes.
  5. Update the connections when services, systems or risks change.

Use the risk assessment and corrective action process to address gaps. The normative requirements are in ISO/IEC 27001; this article offers a practical explanation rather than a reproduction of the standard.

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Frequently asked questions

Must all 93 Annex A controls be implemented?
Annex A is not an instruction to implement every control identically without assessment. Determine which controls are necessary for your scope, risks and applicable requirements, and justify the selection. Exclusions must be defensible. Compare the selected controls with Annex A so that a relevant control is not accidentally overlooked during risk treatment.
Is the SoA the same as a risk treatment plan?
No. The SoA explains necessary controls, their justification and implementation status. A risk treatment plan identifies the changes to make, their owners and timing. Both functions can exist in one system, but their meanings should remain distinct. Planning an action does not demonstrate that its corresponding control is already implemented and operating effectively.

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