ISO 27001:2022 Annex A 5.20 – Addressing Information Security Within Supplier Agreements Explained

Supplier risk is rarely caused by bad intent.
It’s caused by unclear expectations.

Annex A 5.20 exists to ensure that information security requirements are explicitly addressed within supplier agreements, so that both parties understand their obligations before access is granted or services begin.

This control turns supplier security from assumption into agreement.

ISO 27001

Quick Guide: Annex A 5.20 at a Glance

Annex A 5.20 of ISO 27001:2022 focuses on embedding information security requirements into agreements with suppliers.

At a practical level, this means:

  • Defining information security obligations contractually
  • Aligning requirements with supplier risk and criticality
  • Ensuring both parties understand their responsibilities
  • Addressing security throughout the supplier lifecycle
  • Avoiding reliance on verbal or informal assurances

The control does not prescribe specific contract clauses or legal language. It expects organisations to ensure that security requirements relevant to the relationship are agreed, documented, and enforceable.

The emphasis is clarity and proportionality.

In-Depth Guide to Annex A 5.20

What Is Annex A 5.20 and Why Does It Matter?

Suppliers often:

  • Access sensitive information
  • Operate critical systems
  • Provide services essential to availability and resilience

If information security expectations are not defined contractually:

  • Responsibilities are disputed during incidents
  • Gaps appear between policy and practice
  • Enforcement becomes difficult or impossible
  • Risk is discovered too late

Annex A 5.20 ensures that security requirements are established before reliance is created, rather than retrofitted after problems arise.

This control builds directly on supplier risk management by making expectations explicit and enforceable.

How to Implement Annex A 5.20 Effectively

A pragmatic approach to Annex A 5.20 typically includes the following elements.

1. Define Security Requirements Based on Supplier Risk

Security requirements should reflect:

  • The type of service provided
  • The sensitivity of information involved
  • The level of access granted
  • Dependency on supplier availability

Not all suppliers need the same level of contractual control.

2. Address Information Handling and Access

Agreements commonly clarify:

  • What information the supplier may access
  • How information may be used
  • How information must be protected
  • Restrictions on sharing or reuse

Clarity here reduces misuse and misunderstanding.

3. Include Incident Management Expectations

Supplier agreements often define:

  • How security incidents are identified and reported
  • Notification timescales and escalation routes
  • Cooperation during investigation and response

Incident handling is significantly more effective when expectations are agreed in advance.

4. Consider Use of Subcontractors

Where suppliers use subcontractors, agreements may address:

  • Conditions under which subcontracting is permitted
  • Flow-down of security requirements
  • Accountability for subcontractor actions

Unmanaged subcontracting is a common source of hidden risk.

5. Address Change, Audit, and Review

Supplier agreements often include provisions covering:

  • Notification of material changes
  • Rights to review or assess security controls
  • Ongoing assurance mechanisms

This supports security throughout the relationship, not just at onboarding.

6. Plan for Termination and Exit

Security obligations do not end when services stop.

Agreements may define:

  • Return or deletion of information
  • Removal of access rights
  • Ongoing confidentiality obligations
  • Support for transition to alternative providers

Exit is a predictable risk point and should be addressed deliberately.

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

  • Using generic contracts with no security context
  • Tailor requirements to the supplier relationship
  • Relying on supplier certifications alone
  • Define obligations specific to your risk and needs
  • Overloading low-risk suppliers with excessive clauses
  • Apply proportionate requirements
  • Ignoring security at contract renewal or change
  • Reassess requirements when relationships evolve

Contractual clarity prevents operational uncertainty.

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 5.20 is about making security expectations explicit.

When information security is addressed properly within supplier agreements:

  • Accountability is clearer
  • Enforcement is possible
  • Incidents are easier to manage
  • Supplier risk is better controlled

Contracts do not create security on their own, but they define the framework within which security is expected to operate.

That clarity is exactly what Annex A 5.20 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