ISO 27001:2022 Annex A 5.4 – Management Responsibilities Explained

Information security programmes rarely fail because policies are missing.
They fail because management behaviour does not match stated intent.

Annex A 5.4 exists to close that gap.

This control focuses on ensuring that management actively supports, enforces, and demonstrates commitment to information security, rather than delegating it entirely to technical teams or treating it as a compliance exercise.

Security culture starts with leadership behaviour.
Annex A 5.4 makes that explicit.

ISO 27001

Quick Guide: Annex A 5.4 at a Glance

Annex A 5.4 of ISO 27001:2022 addresses management responsibilities for information security.

At a practical level, this means:

  • Management understands its information security responsibilities
  • Security policies and procedures are supported and enforced
  • People are made aware of their security roles before access is granted
  • Adequate time, resources, and attention are provided for security activities
  • Management behaviour reinforces security expectations

The control is not about micromanaging security or turning managers into security specialists. It is about visible ownership and support.

When management treats security seriously, the organisation tends to follow. When it doesn’t, controls are bypassed quietly.

In-Depth Guide to Annex A 5.4

What Is Annex A 5.4 and Why Does It Matter?

Annex A 5.4 ensures that information security is embedded into how the organisation is managed, not bolted on.

Management influence behaviour in ways policies cannot. People take cues from:

  • What leaders prioritise
  • What is challenged
  • What is ignored

If management bypasses security controls, others will follow. If management treats security as optional or inconvenient, security becomes optional.

This control reinforces that information security is a management responsibility, not just a technical one.

How to Implement Annex A 5.4 Effectively

A pragmatic approach to Annex A 5.4 usually includes the following elements.

1. Ensure Management Understands Security Responsibilities

Managers should have a clear understanding of:

  • Information security risks relevant to their areas
  • Policies and procedures they are expected to support
  • Their role in reinforcing security behaviours

This does not require deep technical knowledge, but it does require awareness and accountability.

2. Communicate Expectations Before Access Is Granted

People should understand their security responsibilities before they are given access to systems or information.

This typically includes:

  • Awareness of relevant policies
  • Expectations for handling information
  • Understanding how to report security issues

Setting expectations early reduces friction later.

3. Reinforce Security Through Management Behaviour

Management behaviour sets the tone.

Examples include:

  • Completing mandatory security training themselves
  • Following the same rules as everyone else
  • Supporting security decisions when they are inconvenient

These actions carry far more weight than policy statements.

4. Provide Time and Resources for Security Activities

Security often fails when it competes with delivery without management support.

This control recognises the need for:

  • Adequate resourcing
  • Realistic project timelines
  • Space for security tasks to be completed properly

Without this support, security becomes a shortcut casualty.

5. Support Reporting and Challenge

People need to feel able to raise security concerns without fear of negative consequences.

Management support for:

  • Reporting security issues
  • Raising concerns about policy breaches
  • Challenging unsafe practices

is a critical part of maintaining a healthy security culture.

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

  • Treating security as an IT problem
  • Reinforce that security is a management responsibility
  • Inconsistent management behaviour
  • Align actions with stated security expectations
  • Under-resourcing security activities
  • Plan time and capacity for security work
  • Discouraging challenge or reporting
  • Promote open, supported reporting channels

These challenges are usually governance issues, not technical ones.

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 5.4 is about leadership, not control frameworks.

When management:

  • Takes security seriously
  • Demonstrates consistent behaviour
  • Provides support and resources

security becomes part of normal operations.

If management disengages, no amount of documentation will compensate.

Strong security culture starts at the top — Annex A 5.4 exists to make that unavoidable.

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