ISO 27001:2022 Annex A 5.1 – Information Security Policies Explained

Information security policies are often treated as paperwork. Something you write once, approve, file away, and dust off when an audit appears in the calendar.Annex A 5.1 exists to stop that happening.

This control is about setting clear direction for how information security is managed across the organisation. Not in technical detail. Not as procedures. But as principles that guide consistent, risk-based decisions.

When policies are done well, they simplify security. When they’re done badly, they become shelfware.

ISO 27001

Quick Guide: Annex A 5.1 at a Glance

  • Defining an overarching information security policy that sets intent and direction
  • Supporting this with topic-specific policies where they add clarity
  • Ensuring policies reflect business needs, risk, and legal obligations
  • Making policies accessible and understandable to relevant audiences
  • Keeping them under review so they remain useful as the organisation changes

In-Depth Guide to Annex A 5.1

What Is Annex A 5.1 and Why Does It Matter?

Annex A 5.1 is a foundational governance control. It sets the tone for the entire Information Security Management System (ISMS).

Policies define:

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits

Without clear policies, security becomes inconsistent. Teams improvise. Decisions vary depending on who’s involved. Risk acceptance becomes informal and undocumented.

From a security perspective, that inconsistency is often where incidents start.

From a business perspective, unclear policies lead to friction — security teams blocking work, delivery teams bypassing controls, and leadership stepping in only when something breaks.

A well-designed policy framework:

  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

A common real-world scenario we see is organisations with technically strong controls but weak policy direction. When an exception arises — a supplier request, a new platform, a rushed delivery — there’s no agreed framework to guide the decision. That’s when risk is introduced quietly and unintentionally.

How to Implement Annex A 5.1 Effectively

A practical, security-first approach usually includes the following steps.

1. Define the Purpose of Your Policies

Policies exist to set direction, not to document every control.

Start by being clear about what your policies are there to achieve:

  • Supporting the organisation’s risk appetite
  • Protecting critical information assets
  • Enabling secure delivery, not blocking it

This clarity helps avoid over-engineering and keeps policies focused on outcomes.

2. Align Policies with Business Context and Risk

Policies work best when they reflect how the organisation actually operates.

This includes considering:

  • Business strategy and growth plans
  • Regulatory and contractual obligations
  • The sensitivity of information being handled
  • Key threats and risk themes

A small software company and a regulated financial organisation will legitimately take different approaches — and Annex A 5.1 allows for that.

3. Obtain Visible Management Approval

Management approval is not a formality. It signals ownership.

When leadership approves policies:

  • Expectations are clearer
  • Enforcement is easier
  • Security decisions carry weight

Approval should be explicit and recorded, but it does not need to be complex.

4. Make Policies Usable and Accessible

If policies are hard to find or hard to read, they won’t influence behaviour.

Effective policies are:

  • Written in plain language
  • Available to those who need them
  • Proportionate in length and detail

Many organisations now separate policy from procedure, keeping policies concise and using supporting documentation where detail is needed.

5. Keep Policies Under Meaningful Review

Annex A 5.1 expects policies to remain appropriate as things change.

Triggers for review often include:

  • Significant business change
  • New legal or regulatory requirements
  • Material security incidents
  • Changes in risk profile or technology

Review should focus on relevance, not just timestamps.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Common Challenges and How to Overcome Them

  • Policies written purely for audits
  • Write policies for decision-making first, assurance second
  • Generic, copy-paste policy sets
  • Tailor content to your organisation’s risks and operating model
  • No clear ownership
  • Assign responsibility for policy maintenance and review
  • Too many policies, too much detail
  • Use topic-specific policies only where they add clarity

These issues are rarely technical problems — they’re governance and clarity problems.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Final Recommendations

Annex A 5.1 is not about having “a policy”. It’s about having useful policy direction that supports secure, consistent decision-making.

When implemented well:

  • Security becomes easier to apply
  • Exceptions are handled consistently
  • Accountability is clearer
  • Compliance follows naturally

If policies feel heavy, ignored, or outdated, that’s usually a sign they’ve drifted away from their original purpose.

Get the direction right, keep it relevant, and let the rest of the ISMS build on that foundation.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

The Annex Control Table

ISO 27001:2022 Organisational Controls
ISO 27001:2022 Technological Controls