ISO 27001:2022 Annex A 5.26 – Response to Information Security Incidents Explained

Incident response is where preparation is tested under pressure.

Annex A 5.26 exists to ensure organisations respond to information security incidents in a controlled, consistent, and effective way, limiting impact and restoring control without improvisation or confusion.

This control focuses on execution. It takes the planning and preparation established earlier and applies it when incidents actually occur.

ISO 27001

Quick Guide: Annex A 5.26 at a Glance

Annex A 5.26 of ISO 27001:2022 addresses the response to information security incidents.

At a practical level, this means:

  • Responding to incidents in line with defined procedures
  • Containing and mitigating the impact of incidents
  • Coordinating technical, operational, and management actions
  • Ensuring incidents are handled by competent personnel
  • Restoring control and stability in a timely manner

The control does not require a dedicated incident response team or enterprise tooling. It expects organisations to follow their agreed incident management approach and apply it effectively when incidents arise.

In-Depth Guide to Annex A 5.26

What Is Annex A 5.26 and Why Does It Matter?

When an incident occurs, organisations are under pressure to:

  • Act quickly
  • Minimise disruption
  • Protect information
  • Communicate accurately

Without a structured response:

  • Actions are duplicated or missed
  • Evidence is lost
  • Decisions are delayed or inconsistent
  • Recovery takes longer than necessary

Annex A 5.26 ensures that incidents are handled deliberately rather than reactively, reducing both immediate impact and longer-term consequences.

This control applies to:

  • Confirmed information security incidents
  • Incidents arising from events or weaknesses
  • Incidents involving internal or external parties

Consistency matters more than speed alone.

How to Implement Annex A 5.26 Effectively

A pragmatic approach to Annex A 5.26 typically includes the following elements.

1. Contain and Mitigate the Incident

Initial response activities usually focus on:

  • Limiting further damage
  • Preventing spread or escalation
  • Protecting affected systems and information

Containment actions should be proportionate and aligned with the nature of the incident.

2. Follow Defined Incident Response Procedures

Response should be guided by established procedures rather than ad-hoc decisions.

Procedures often support:

  • Coordination between teams
  • Clear escalation routes
  • Consistent decision-making
  • Controlled communication

Using agreed processes reduces confusion under pressure.

3. Ensure Appropriate Competence

Incidents should be handled by personnel with appropriate skills and authority.

This may involve:

  • Technical specialists
  • Operational managers
  • Legal, regulatory, or communications support

Competence and coordination are more important than formal role titles.

4. Collect and Preserve Evidence

Where relevant, evidence should be collected and preserved during response.

This supports:

  • Incident analysis
  • Regulatory or legal requirements
  • Disciplinary or contractual action
  • Learning and improvement

Evidence handling should be deliberate and documented.

5. Communicate on a Need-to-Know Basis

Communication during incidents should be controlled.

Organisations typically:

  • Limit information sharing to those who need it
  • Coordinate internal and external messaging
  • Consider legal and regulatory obligations

Uncontrolled communication often increases risk.

6. Restore Control and Stability

Incident response aims to restore control, not just close tickets.

This may include:

  • Reinstating secure operations
  • Applying temporary or permanent fixes
  • Confirming systems and information are protected

Restoration should be verified, not assumed.

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.

Practical Considerations During Response

Effective incident response balances:

  • Speed, to limit harm
  • Accuracy, to avoid mistakes
  • Coordination, to prevent conflicting actions

Logging actions and decisions as they occur supports:

  • Post-incident review
  • Accountability
  • Continuous improvement

Annex A 5.26 recognises that response quality directly influences both impact and recovery time.

Common Challenges and How to Overcome Them

  • Improvising responses under pressure
  • Follow defined incident procedures
  • Involving too many people too quickly
  • Communicate on a need-to-know basis
  • Losing evidence during containment
  • Balance mitigation with evidence preservation
  • Focusing only on technical recovery
  • Coordinate technical, operational, and governance actions

Most response failures are coordination failures.

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 5.26 is about responding with control, not panic.

When incident response is handled effectively:

  • Impact is reduced
  • Recovery is faster
  • Decisions are defensible
  • Learning is enabled
  • Organisational resilience improves

Incidents will happen.
Annex A 5.26 ensures that when they do, the organisation responds calmly, competently, and consistently.

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