ISO 27001:2022 Annex A 5.9 – Inventory of Information and Other Associated Assets Explained

You cannot protect what you do not know you have.

Annex A 5.9 exists to ensure organisations identify, understand, and take ownership of their information and associated assets, so that security controls are applied deliberately rather than blindly.

This control is foundational. Every other security decision - risk assessment, classification, access control, incident response - depends on knowing what assets exist and who is responsible for them.

ISO 27001

Quick Guide: Annex A 5.9 at a Glance

Annex A 5.9 of ISO 27001:2022 focuses on maintaining an inventory of information and other associated assets, including ownership.

At a practical level, this means:

  • Identifying information and associated assets that support the organisation
  • Understanding where those assets are stored, processed, or transmitted
  • Assigning ownership and accountability for assets
  • Keeping asset information sufficiently accurate and current
  • Using the inventory to support risk and security decisions

The control does not mandate a single inventory, a specific tool, or exhaustive technical detail. The level of formality should be proportionate to the organisation’s size, complexity, and risk profile.

The outcome matters more than the format.

In-Depth Guide to Annex A 5.9

What Is Annex A 5.9 and Why Does It Matter?

Information assets are not limited to databases and servers.

They include:

  • Business data
  • Customer and personal information
  • Applications and systems
  • Infrastructure and platforms
  • Supporting components and dependencies

Without a clear understanding of these assets:

  • Risks are assessed incompletely
  • Controls are applied inconsistently
  • Critical systems are overlooked
  • Incident response and recovery are slowed

Annex A 5.9 ensures organisations establish visibility and ownership over the assets that matter to their operations and security.

It also supports better decision-making by making asset value and importance explicit.

How to Implement Annex A 5.9 Effectively

A pragmatic approach to Annex A 5.9 usually includes the following elements.

1. Identify Information and Associated Assets

Start by identifying assets that are important to the organisation’s objectives and information security.

This often includes:

  • Information itself (data sets, records, intellectual property)
  • Systems and applications
  • Infrastructure and platforms
  • Supporting components such as databases, storage, or integrations

The focus should be on relevance, not exhaustiveness.

2. Assign Ownership and Accountability

Each asset should have an identified owner who is accountable for its protection.

Ownership typically includes responsibility for:

  • Understanding the asset’s value and sensitivity
  • Ensuring appropriate safeguards are applied
  • Supporting classification and access decisions
  • Considering risks throughout the asset’s lifecycle

Ownership does not imply technical administration — it implies accountability.

3. Maintain an Appropriate Inventory

Asset information should be recorded in a way that is:

  • Understandable
  • Accessible
  • Aligned with how the organisation operates

Some organisations maintain multiple inventories for different purposes. That is acceptable, provided information is consistent and usable.

The control does not require a single, centralised register.

4. Keep Asset Information Current

Asset inventories lose value quickly if they are not maintained.

Common triggers for review include:

  • System changes or new deployments
  • Asset retirement or disposal
  • Organisational change
  • Incident or audit findings

Updates should be part of normal operational processes where possible.

5. Use the Inventory to Support Security Decisions

An inventory is not an end in itself.

It should support:

  • Risk assessment and treatment
  • Information classification
  • Access control decisions
  • Incident response and recovery planning

If the inventory is not being used, it is likely too complex or misaligned.

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

  • Trying to catalogue everything in technical detail
  • Focus on assets that matter to security and operations
  • Inventories that fall out of date quickly
  • Integrate updates into change and lifecycle processes
  • Unclear or nominal asset ownership
  • Assign accountability to people who understand business impact
  • Treating the inventory as a compliance exercise
  • Use it as a decision-support tool

Asset management works best when it is practical, not theoretical.

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 5.9 is about visibility, ownership, and informed decision-making.

When information and associated assets are clearly identified:

  • Risks are easier to understand
  • Controls are applied more consistently
  • Incidents are handled more effectively
  • Security effort is better prioritised

An asset inventory does not need to be perfect. It needs to be useful and current.

That is the outcome Annex A 5.9 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