ISO 27001:2022 Annex A 8.31 – Separation of Development, Test and Production Environments

Many security incidents are not cyber-attacks.
They are changes made in the wrong environment.

Annex A 8.31 exists to help organisations reduce operational and security risk by separating development, testing, and production environments, protecting live systems and real data from accidental or unauthorised impact.

This control is about containment and discipline, not slowing delivery.

ISO 27001

Quick Guide: Annex A 8.31 at a Glance

Annex A 8.31 focuses on separating environments used for development, testing, and live operations.

In practice, this includes:

  • Keeping development, test, and production environments distinct
  • Restricting access between environments
  • Preventing unapproved changes to live systems
  • Protecting production data from misuse
  • Ensuring changes are tested before release

The control does not require physical separation.
It supports logical, technical, or procedural separation appropriate to risk.

In-Depth Guidance on Annex A 8.31

Why Environment Separation Matters

Development and testing activities naturally involve:

  • Frequent changes
  • Elevated access
  • Debugging tools
  • Unstable or incomplete configurations

If these activities interact directly with production:

  • Availability may be affected
  • Confidential data may be exposed
  • System integrity may be compromised
  • Security controls may be bypassed

Annex A 8.31 helps organisations preserve confidentiality, integrity, and availability by isolating risky activities from live operations.

This control replaces ISO 27001:2013 Annex A 12.1.4 and A 14.2.6, consolidating environment separation into a single, clearer requirement.

Practical Implementation Guidance

1. Define Environment Boundaries Clearly

Organisations should clearly define:

  • Development environments
  • Test or staging environments
  • Production environments

Environment purpose should be obvious to users, including clear labelling in menus and interfaces, to reduce the likelihood of error.

Ambiguity leads to mistakes.

2. Apply Appropriate Levels of Separation

Separation may be achieved through:

  • Separate physical infrastructure
  • Virtual machines or containers
  • Separate cloud tenancies or subscriptions
  • Logical segregation supported by strong access controls

The degree of separation should reflect:

  • Sensitivity of data
  • Business criticality
  • Impact of failure

Higher risk environments justify stronger segregation.

3. Control Access to Environments

Access to each environment should be:

  • Authorised
  • Role-appropriate
  • Reviewed periodically

Individuals should not routinely have unrestricted access across development and production environments.
Where access overlaps, additional approval and oversight helps reduce risk.

This supports separation of duties and accountability.

4. Prevent Testing in Production by Default

Testing activities are generally more appropriate in non-production environments.

Where testing in production is unavoidable:

  • It should be explicitly defined
  • Authorised in advance
  • Controlled and monitored

Unplanned testing in live environments introduces unnecessary risk.

5. Protect Production Data

Production data is particularly sensitive.

Organisations should consider:

  • Avoiding use of live data in development or test environments
  • Applying masking or anonymisation where data is required
  • Ensuring equivalent security controls exist if production data is reused

Uncontrolled use of live data is a common source of data protection failures.

6. Control Movement Between Environments

Movement of software, configuration, or code between environments should be:

  • Authorised
  • Controlled
  • Traceable

This helps ensure:

  • Changes have been tested
  • Unauthorised changes are prevented
  • Rollback and investigation are possible

Direct changes in production bypass essential safeguards.

7. Restrict Development Tools in Production

Development tools such as:

  • Compilers
  • Editors
  • Debugging utilities

are generally unnecessary in production environments.

Limiting these tools reduces attack surface and accidental misuse.

8. Secure Development and Test Environments

Although non-production, development and test environments still require protection.

Organisations should consider:

  • Secure configuration of systems
  • Patch management for development tools and libraries
  • Access control and monitoring
  • Backup and recovery arrangements

Lower criticality does not mean no security.

9. Monitor and Review Environment Use

Access and activity across environments should be:

  • Logged
  • Reviewed periodically
  • Investigated where anomalies occur

Monitoring supports detection of misuse, misconfiguration, and policy drift.

10. Include Third Parties and Suppliers

Annex A 8.31 applies equally to:

  • Outsourced development
  • Managed testing services
  • Cloud-hosted environments

Suppliers should operate segregated environments and follow agreed access and data-handling rules.

External delivery does not reduce internal accountability.

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

  • Developers working directly in production
  • Apply least privilege and controlled access
  • Production data copied freely into test environments
  • Mask, anonymise, or restrict data use
  • Emergency fixes applied without oversight
  • Use defined emergency change processes
  • Environment boundaries not documented
  • Maintain diagrams and clear definitions

Environment separation failures are predictable and preventable.

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 8.31 is about keeping instability away from live systems.

When development, test, and production environments are separated effectively:

  • Availability incidents reduce
  • Data protection risk is controlled
  • Change becomes safer and more consistent
  • Audit and assurance confidence improves

Development is where experimentation belongs.
Production is where control matters most.

Annex A 8.31 ensures organisations do not blur that line.

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