ISO/IEC 27001:2022 Readiness.

International Information Security Management System standard recognized by enterprise buyers globally

Readiness guide

ISO/IEC 27001:2022 is the international standard for Information Security Management Systems (ISMS). It is published jointly by the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC), and certification is issued by accredited third-party certification bodies (e.g., BSI, Bureau Veritas, DNV, TÜV) — not by ISO itself.

Unlike SOC 2 (which is an attestation report) or HIPAA (which is a regulation), ISO 27001 is a management-system standard. Certification means an accredited body has audited that you have an ISMS in place, that the ISMS conforms to the standard's requirements, and that you have selected and operated a relevant set of controls from Annex A.

The 2022 revision tightened controls (down to 93 from the 2013 version's 114) and reorganized them into 4 themes (Organizational, People, Physical, Technological). Companies certified under 2013 must transition to 2022 by October 2025.

Source: ISO/IEC 27001:2022 standard page · ISO/IEC 27002:2022 (controls guidance)

ISO 27001 is the dominant security framework outside the US. European, Middle Eastern, and Asian enterprise buyers often require it as a procurement gate. Government contracts in many jurisdictions require it. SaaS companies with substantial non-US enterprise customers usually need it within 18 months of those customers materializing.

You probably need ISO 27001 if: your enterprise prospects are based in Europe, the UK, the Middle East, or Asia; your sales team is hearing “do you have ISO 27001?” in security questionnaires; or you are competing against vendors who already have it.

You probably do NOT need ISO 27001 yet if: your customer base is primarily US-based and SOC 2 satisfies their procurement teams. SOC 2 + ISO 27001 is the gold-standard combination for global enterprise SaaS — but SOC 2 alone is sufficient for most US-only customer bases.

Cloud Upload is not a certification body. The certification audit must come from an accredited body. We prepare your ISMS, scope, controls, evidence, and risk treatment plan that the certification body will audit against.

Three concrete outputs from a readiness engagement:

  • Output A

    Defined ISMS scope

    Documented scope of the Information Security Management System — which products, locations, employees, and data flows are in scope. Scope drives every other deliverable; getting it wrong inflates the audit cost and delays certification.

  • Output B

    Statement of Applicability (SoA) + risk treatment plan

    For each of the 93 Annex A controls, the SoA documents whether it applies, why, and how it is implemented. The SoA is the fingerprint of your control environment — see our writeup Why your ISO 27001 Statement of Applicability keeps drifting.

  • Output C

    ISMS operational artifacts

    Risk register current and reviewed, internal audit program in place, management review meetings documented, corrective action register active. The ISMS is a living management system — auditors look for evidence of operation, not just policy existence.

Certification audits run in two stages. Stage 1 is a documentation review (4-8 weeks before Stage 2). Stage 2 is on-site/remote audit of the operating ISMS. Surveillance audits run annually for 3 years; recertification audit at year 3.

The 93 Annex A controls span 4 themes. Technological controls map heavily to CC360° categories; Organizational, People, and Physical controls run alongside.

Section Title CC360° category
A.5 Organizational controls (37 controls) Cross-cutting (policies, vendor management, BCP — outside CC360°)
A.6 People controls (8 controls) Cross-cutting (HR, training, awareness — outside CC360°)
A.7 Physical controls (14 controls) Inherited from cloud provider
A.8 Technological controls (34 controls) Maps to CC360° §1–§8 — see breakdown below
A.8.1–A.8.3 User endpoint, privileged access, restriction §1 IAM
A.8.4–A.8.7 Source code, change management, dev/test, malware §7 Workload Security
A.8.8–A.8.10 Vulnerability management, configuration, deletion §7 Workload Security · §3 Data
A.8.11–A.8.13 Data masking, leakage, backup §3 Data · §6 Architecture & Resilience
A.8.14–A.8.18 Redundancy, logging, monitoring, sync, privileged tools §4 Logging & Detection · §6 Architecture & Resilience
A.8.19–A.8.27 Software install, network security, services, segregation, web filter, crypto, dev lifecycle, secure coding, app security req §2 Network · §7 Workload Security · §3 Data (crypto)
A.8.28–A.8.34 Outsourced dev, test environments, business app prep, change/test, change management, test data, audit considerations §7 Workload Security · §4 Logging & Detection

The Statement of Applicability documents Cloud Upload's position on each of the 93 controls. Cloud-native SaaS companies typically have ~80 applicable controls; the rest (e.g., physical media disposal, paper records) are excluded with documented rationale.

A first-time ISO 27001 readiness engagement is typically 12 to 20 weeks, depending on starting state and scope size.

  1. Weeks 1-3

    Scope definition & ISMS framing

    Define ISMS scope (which products, locations, data flows, employees). Identify interested parties and their requirements. Establish ISMS objectives. CloudCheck 360° pass surfaces technical baseline.

  2. Weeks 3-8

    Risk assessment & treatment

    ISO 27005-aligned risk assessment. Risk treatment plan documented per identified risk (treat / accept / avoid / transfer). Statement of Applicability drafted with rationale per Annex A control.

  3. Weeks 6-14

    Control implementation & policy

    Technical controls implemented or remediated. Policies drafted (Information Security Policy, Access Control Policy, Cryptography Policy, BCP, Supplier Relationship Management Policy, etc.). Internal audit program established.

  4. Weeks 14-18

    Internal audit + management review

    First internal audit cycle completed against ISMS. Management review meeting held with documented minutes. Corrective actions tracked. ISMS demonstrably operating.

  5. Weeks 18-20

    Certification body selection & Stage 1 prep

    Cloud Upload introduces 2-3 vetted UKAS/ANAB-accredited certification bodies. Stage 1 audit scheduled. Cloud Upload remains available for engineering questions during Stage 1 and Stage 2.

Stage 1 → Stage 2 typically runs 4-8 weeks. Surveillance audits annually, recertification at year 3.

  • Statement of Applicability written once, never updated.

    The SoA is supposed to be the fingerprint of your control environment — current and accurate. In most companies it's a snapshot from the year of certification. Changes to controls, scope, or environment should trigger SoA updates. The fix is making SoA review a quarterly activity tied to change management.

  • Risk register exists, risk treatment plan does not.

    Most companies maintain a risk register. The standard requires a risk treatment plan — for each risk, the documented treatment decision (accept / mitigate / transfer / avoid) with owner and target date. The fix is a single column added to the risk register, populated and reviewed quarterly.

  • Internal audit program theoretical.

    ISMS requires an internal audit program. Many companies have a policy that says “we will internally audit annually” and no evidence of any audit ever performed. Auditors specifically ask for internal audit reports. The fix is scheduling a quarterly internal audit (one ISMS section per quarter) with documented findings.

  • Management review meetings never held.

    ISMS requires periodic management review. Many companies skip this entirely. The standard expects documented minutes covering ISMS performance, audit results, risk treatment progress, change to context. The fix is quarterly 60-minute leadership meeting with template agenda and signed minutes.

  • Supplier risk reviewed at onboarding only.

    A.5.19-A.5.22 require supplier risk management as ongoing activity. Most companies do an initial supplier review during onboarding and never revisit. Auditors look for annual reassessments, particularly for suppliers handling customer data.

  • Stage 1 vs Stage 2 audit?

    Stage 1 is a documentation review — the certification body confirms your ISMS is documented and ready to be audited. Stage 2 is the actual conformance audit — sampling controls, interviewing personnel, reviewing evidence. Stage 1 typically 1-2 days; Stage 2 typically 3-5 days for a small SaaS company.

  • Which certification body should we use?

    Choose an accredited body (UKAS in the UK, ANAB in the US, COFRAC in France, etc.). Cloud Upload is vendor-neutral; we typically introduce 2-3 candidates and let you select based on geography, audit style, and budget. Premium global bodies (BSI, DNV, Bureau Veritas) cost more; regional bodies (Nimble, A-LIGN) are competitive.

  • How much does ISO 27001 certification cost?

    Stage 1 + Stage 2 typically $20,000-$60,000 depending on scope and certification body. Surveillance audits annually $8,000-$20,000. Recertification at year 3 similar to Stage 2 cost. Readiness work (Cloud Upload + your team time) is separate — usually 12-20 weeks of engagement.

  • Can we use ISO 27001 instead of SOC 2 for US customers?

    Sometimes. US enterprise buyers increasingly accept ISO 27001 — particularly if you have a SOC 2 + ISO 27001 mapping document. Most growing SaaS companies eventually need both. Significant overlap in controls means the second framework is faster than the first — typically 60-70% control reuse.

  • What about ISO 27017 and ISO 27018?

    ISO 27017 (cloud security) and ISO 27018 (cloud privacy) are extension standards specifically for cloud service providers. They are NOT standalone certifications — they extend the base ISO 27001 certification scope. Cloud-native SaaS companies often add both extensions during the Stage 2 audit.

  • When does the 2013 → 2022 transition deadline hit?

    October 2025. Companies certified under ISO 27001:2013 must transition to ISO 27001:2022 by then or lose certification. The transition is non-trivial — A.5 → A.8 control reorganization changes the SoA structure substantially.

Primary sources: ISO/IEC 27001:2022 · ISO/IEC 27002:2022 controls guidance · CloudCheck 360° methodology · Why your ISO 27001 SoA keeps drifting · SOC 2 readiness guide · NIST / CIS guide

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The patterns in this guide come from real engagements. To see how your environment compares — and which gaps would land in your readiness report — start with a free scan or talk to us about a manual engagement.