ISO 27001:2022 Annex A 5.16 – Identity Management Explained

Identity is the gateway to access.

Annex A 5.16 exists to ensure organisations manage identities in a controlled and consistent way across their full lifecycle, so that access to information and systems is attributable, authorised, and traceable.

This control applies to both human and non-human identities and underpins almost every other access-related control.

ISO 27001

Quick Guide: Annex A 5.16 at a Glance

Annex A 5.16 of ISO 27001:2022 focuses on identity management.

At a practical level, this means:

  • Identifying who or what is accessing systems and information
  • Managing identities from creation through to removal
  • Ensuring identities are uniquely assigned and traceable
  • Treating human and non-human identities appropriately
  • Preventing identity sprawl, duplication, and misuse

The control does not mandate specific identity technologies or platforms. It expects organisations to apply clear, risk-based identity lifecycle management aligned with how their environment operates.

In-Depth Guide to Annex A 5.16

What Is Annex A 5.16 and Why Does It Matter?

Every access decision relies on identity.

If identities are poorly managed:

  • Access cannot be reliably attributed
  • Orphaned or unused identities persist
  • Privileged access is harder to control
  • Incident investigation becomes difficult

Annex A 5.16 ensures identities are deliberate, justified, and governed, rather than accumulated over time without oversight.

This control provides the structural foundation for authentication, authorisation, and access review.

How to Implement Annex A 5.16 Effectively

A pragmatic approach to Annex A 5.16 typically includes the following elements.

1. Define an Identity Lifecycle

Organisations should define how identities are:

  • Requested
  • Approved
  • Created
  • Modified
  • Disabled or removed

This lifecycle should apply to all identity types, with variation only where risk or function justifies it.

2. Ensure One Identity per Entity

Each identity should map clearly to a single entity.

This supports:

  • Accountability
  • Traceability
  • Reliable audit and investigation

Shared identities should only be used where there is a clear operational requirement and appropriate controls are applied.

3. Distinguish Between Human and Non-Human Identities

Non-human identities (such as applications, services, or devices) introduce different risks.

Organisations typically:

  • Use separate approval and registration processes
  • Limit scope and permissions tightly
  • Review non-human identities regularly

Treating non-human identities the same as users often leads to excessive privilege.

4. Verify Before Creating Identities

Identity creation should be based on a clear business need.

This usually involves:

  • Verifying the entity
  • Confirming authority and role
  • Ensuring access is justified

Unnecessary identities increase complexity and risk.

5. Remove or Disable Identities Promptly

When identities are no longer required, they should be disabled or removed.

Common triggers include:

  • Role changes
  • Contract completion
  • System retirement
  • Leavers

Delayed removal is a common cause of unauthorised access.

6. Maintain Visibility and Records

Organisations should maintain sufficient records to understand:

  • What identities exist
  • What they are used for
  • When they were created or changed

Visibility supports governance, review, and incident response.

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

  • Identity sprawl over time
  • Apply lifecycle controls and periodic review
  • Shared or duplicate identities
  • Enforce clear ownership and justification
  • Non-human identities with excessive access
  • Treat service identities as high-risk by default
  • Weak coordination between HR and IT
  • Align identity changes with joiner, mover, leaver processes

Identity risk grows quietly when left unmanaged.

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 5.16 is about maintaining control over who or what can act within your environment.

When identity management is applied effectively:

  • Access becomes traceable and accountable
  • Privileged activity is easier to control
  • Other access controls operate more reliably
  • Security incidents are easier to investigate

Identity management does not need to be complex. It needs to be intentional, governed, and consistently applied.

That is the outcome Annex A 5.16 is designed to achieve.

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