ISO 27001:2022 Annex A 5.36 – Compliance with Policies, Rules and Standards for Information Security Explained

Security controls only work if people actually follow them.

Annex A 5.36 exists to ensure organisations monitor, review, and enforce compliance with their own information security policies, rules, and standards, and take corrective action when deviations are identified.

This control is about closing the gap between documented intent and operational reality.

ISO 27001

Quick Guide: Annex A 5.36 at a Glance

Annex A 5.36 of ISO 27001:2022 focuses on compliance with internal information security policies, rules, and standards.

At a practical level, this means:

  • Ensuring information security policies and standards are followed in practice
  • Assigning responsibility for monitoring compliance
  • Reviewing compliance periodically and after significant change
  • Identifying and addressing non-compliance
  • Taking corrective action to prevent recurrence

The control does not require constant monitoring or technical audits of every system. It expects a structured, risk-based approach to confirming that agreed security rules are being applied as intended.

In-Depth Guide to Annex A 5.36

What Is Annex A 5.36 and Why Does It Matter?

Most organisations have documented security policies and standards.

However, common failures include:

  • Policies existing but not being followed
  • Local workarounds becoming normal practice
  • Controls degrading quietly over time
  • Non-compliance only being discovered during incidents or audits

Annex A 5.36 ensures organisations actively check whether their own rules are being complied with, rather than assuming that documentation alone delivers security.

This control replaces and consolidates compliance-focused controls from ISO 27001:2013, reinforcing that ongoing compliance is both a preventive and corrective activity.

How to Implement Annex A 5.36 Effectively

A pragmatic approach to Annex A 5.36 typically includes the following elements.

1. Make Policies, Rules and Standards Accessible

People cannot comply with rules they cannot find or understand.

Organisations should ensure that:

  • Information security policies and standards are available
  • Content is understandable and relevant
  • Ownership and applicability are clear

Accessibility supports accountability.

2. Assign Responsibility for Compliance Oversight

Compliance monitoring should have clear ownership.

This often sits with:

  • Information security management
  • Operational management
  • Or a defined governance or assurance function

Ownership ensures compliance is actively managed, not passively assumed.

3. Monitor and Review Compliance Periodically

Compliance should be reviewed at planned intervals.

Reviews may include:

  • Management checks
  • Process or control reviews
  • Targeted technical reviews
  • Evidence-based sampling

The depth of review should reflect risk, not uniformity.

4. Identify and Assess Non-Compliance

Where non-compliance is identified, organisations should:

  • Understand what has deviated from policy or standard
  • Assess the associated information security risk
  • Determine whether the deviation is isolated or systemic

Non-compliance is a signal, not all signals carry the same weight.

5. Determine and Implement Corrective Action

Where corrective action is appropriate, organisations typically:

  • Identify root causes
  • Decide what action is proportionate
  • Assign responsibility and timescales
  • Implement changes deliberately

Corrective action should address causes, not just symptoms.

6. Review the Effectiveness of Corrective Actions

After action is taken, organisations should consider:

  • Whether compliance has improved
  • Whether risk has been reduced
  • Whether additional action is required

Unverified corrective action often becomes assumed success.

Practical Considerations

Annex A 5.36 does not require organisations to:

  • Achieve perfect compliance at all times
  • Eliminate all deviations immediately
  • Apply the same review depth everywhere

It does expect organisations to:

  • Know where non-compliance exists
  • Understand the associated risk
  • Act deliberately and proportionately

This control supports continuous improvement, not punitive enforcement.

Common Challenges and How to Overcome Them

  • Assuming documented policies equal compliance
  • Actively review how controls operate in practice
  • Inconsistent compliance checks across teams
  • Apply a structured, risk-based review approach
  • Treating non-compliance as a failure
  • Use it as an opportunity to improve controls
  • Failing to follow up corrective actions
  • Track actions through to completion and review effectiveness

Compliance degrades when it is not observed.

Final Recommendations

Annex A 5.36 is about keeping security controls alive.

When compliance with policies, rules, and standards is monitored and managed:

  • Security controls remain effective
  • Drift is detected early
  • Risk is reduced proactively
  • Confidence in the ISMS increases

Policies define intent.
Annex A 5.36 ensures that intent is realised in practice.

The Annex Control Table

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