ISO 27001:2022 Annex A 8.29 – Security Testing in Development and Acceptance Explained

Most security failures are discovered after deployment — when fixing them is slow, expensive, and disruptive.

Annex A 8.29 exists to ensure organisations test security deliberately during development and before acceptance, identifying weaknesses early and confirming that systems meet defined security requirements before they go live.

This control is about finding problems before attackers do.

ISO 27001

Quick Guide: Annex A 8.29 at a Glance

Annex A 8.29 of ISO 27001:2022 focuses on security testing during development and acceptance.

At a practical level, this means:

  • Planning and performing security testing for new and changed systems
  • Verifying security requirements before systems enter production
  • Identifying vulnerabilities in code, configuration, and design
  • Testing both internally developed and externally supplied systems
  • Ensuring security testing results inform acceptance decisions

The control does not mandate specific tools or tests. It expects risk-based, structured security testing that is appropriate to the system and its exposure.

In-Depth Guide to Annex A 8.29

What Is Annex A 8.29 and Why Does It Matter?

Systems frequently fail because:

  • Security testing was incomplete
  • Testing focused only on functionality
  • Acceptance decisions ignored known weaknesses
  • Supplier assurances were accepted without verification

When security testing is weak:

  • Vulnerabilities reach production
  • Sensitive data is exposed
  • Incidents occur immediately after go-live
  • Remediation costs escalate rapidly

Annex A 8.29 ensures organisations treat security testing as a core delivery activity, not an optional final check.

This control replaces ISO 27001:2013 Annex A 14.2.8 and 14.2.9, consolidating system security testing and acceptance testing into a single, clearer requirement.

How to Implement Annex A 8.29 Effectively

A pragmatic approach to Annex A 8.29 typically includes the following elements.

1. Define a Security Testing Approach

Organisations should define how security testing is performed, including:

  • When testing occurs
  • What types of testing are used
  • Who is responsible for testing and approval

The approach should reflect:

  • System criticality
  • Information sensitivity
  • Exposure to users and networks

Security testing should scale with risk.

2. Integrate Security Testing Into Development

Security testing should occur during development, not just at the end.

This may include:

  • Code review
  • Automated security testing
  • Configuration validation
  • Early vulnerability identification

Finding issues during development is cheaper and faster than post-deployment remediation.

3. Define Security Acceptance Criteria

Annex A 8.29 expects systems to meet defined security requirements before acceptance.

Acceptance criteria may include:

Acceptance without security criteria is not acceptance.

4. Develop a Security Testing Plan

Where risk justifies it, organisations should develop a security testing plan that defines:

  • Scope of testing
  • Test methods and techniques
  • Expected inputs and outcomes
  • Criteria for evaluating results
  • Actions to be taken if issues are identified

Plans provide structure and repeatability.

5. Perform Appropriate Types of Security Testing

Security testing may include:

  • Code review
  • Vulnerability scanning
  • Configuration assessment
  • Penetration testing
  • Security-focused functional testing

The mix of testing should be proportionate to:

  • System exposure
  • Threat landscape
  • Business impact

Testing everything everywhere is unrealistic. Testing nothing is indefensible.

6. Test Authentication, Access Control, and Cryptography

Annex A 8.29 explicitly supports testing controls such as:

These controls are common failure points and should be verified, not assumed.

7. Validate Secure Configuration

Testing should confirm that:

  • Systems are hardened appropriately
  • Default or insecure configurations are removed
  • Network and firewall rules align with design

Misconfiguration is one of the most common post-deployment weaknesses.

8. Use Independent Acceptance Testing Where Appropriate

For higher-risk systems, acceptance testing should be:

  • Independent of the development team
  • Objective and evidence-based

Independence reduces confirmation bias and missed issues.

9. Record and Review Security Testing Results

Organisations should retain evidence of:

  • Tests performed
  • Issues identified
  • Decisions taken
  • Actions completed

Records support:

  • Audit and assurance
  • Accountability
  • Continuous improvement

Undocumented testing is indistinguishable from no testing.

10. Address Identified Issues Before Acceptance

Where testing identifies weaknesses, organisations should:

  • Assess risk
  • Remediate issues where required
  • Apply compensating controls if remediation is deferred

Acceptance decisions should be explicit and risk-informed.

11. Apply Security Testing to Changes and Updates

Annex A 8.29 applies not only to new systems, but also to:

  • System upgrades
  • Major configuration changes
  • New releases or versions

Changes reintroduce risk and require testing proportionate to their impact.

12. Control Testing for Outsourced and Supplier Systems

Where systems are developed or supplied externally, organisations should:

  • Define security testing requirements contractually
  • Verify supplier testing where appropriate
  • Perform independent testing for critical systems

Supplier testing does not remove organisational responsibility.

13. Use Appropriate Test Environments

Security testing should be performed in:

  • Controlled environments
  • Configurations representative of production

Test environments should themselves be:

  • Secured
  • Managed
  • Monitored

Uncontrolled test environments create new risk.

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

Annex A 8.29 does not require:

  • Penetration testing for every system
  • Excessive testing for low-risk changes
  • Specialist tooling in all cases

It does require organisations to:

  • Test security deliberately
  • Base acceptance on evidence
  • Avoid deploying known weaknesses

Most incidents occur because issues were known — and ignored.

Common Challenges and How to Overcome Them

  • Security testing left until the end
  • Integrate testing throughout development
  • Acceptance based on functionality only
  • Define and enforce security acceptance criteria
  • Supplier assurances accepted without evidence
  • Verify security testing outcomes
  • Test results not acted upon
  • Link testing to remediation and acceptance decisions

Security testing fails when it has no consequence.

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 8.29 is about confidence before deployment.

When security testing in development and acceptance is implemented effectively:

  • Vulnerabilities are identified earlier
  • Deployment risk is reduced
  • Incidents immediately after go-live are less likely
  • Assurance becomes evidence-based

You don’t deploy systems hoping they are secure.
You deploy them knowing what has been tested — and why.

Annex A 8.29 ensures organisations do exactly that.

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