ISO 27001:2022 Annex A 8.32 – Change Management Explained

Most security incidents are not caused by new threats.
They are caused by poorly controlled change.

Annex A 8.32 exists to ensure organisations manage changes to information systems in a controlled, consistent, and risk-aware way, protecting confidentiality, integrity, and availability while still allowing the business to evolve.

This control is about control and predictability, not blocking progress.

ISO 27001

Quick Guide: Annex A 8.32 at a Glance

Annex A 8.32 focuses on change management for information processing facilities and systems.

In practice, this includes:

  • Assessing the security and business impact of changes
  • Authorising changes before implementation
  • Testing changes prior to deployment
  • Communicating changes to relevant stakeholders
  • Maintaining records of changes and outcomes
  • Updating documentation, continuity, and recovery arrangements

The control applies to technical, procedural, and system-level changes, regardless of whether they are large or small.

In-Depth Guide to Annex A 8.32

Why Change Management Is a Security Control

Change introduces uncertainty.

Uncontrolled or poorly assessed changes can:

  • Weaken security controls
  • Introduce vulnerabilities
  • Disrupt availability
  • Break dependencies between systems
  • Undermine recovery and continuity arrangements

Annex A 8.32 ensures organisations understand the impact of change before it happens, rather than investigating it after something goes wrong.

This control replaces ISO 27001:2013 Annex A 12.1.2, 14.2.2, 14.2.3, and 14.2.4, consolidating change-related requirements into a single control aligned to modern environments.

Practical Implementation Guidance

1. Define What Constitutes a Change

Organisations should define what types of activity are treated as change, including:

  • System configuration changes
  • Software upgrades and patches
  • Infrastructure modifications
  • Introduction of new systems or services
  • Decommissioning of systems

Clarity avoids accidental bypass of controls.

2. Assess the Impact of Proposed Changes

Before implementation, changes should be assessed to understand:

  • Information security impact
  • Business and operational impact
  • Dependencies on other systems or services
  • Impact on users, suppliers, and customers

Impact assessment supports proportionate decision-making.

3. Apply Appropriate Authorisation

Changes should be authorised by individuals with suitable responsibility and understanding of the risk.

Authorisation helps ensure:

  • Risk is consciously accepted
  • Changes align with business priorities
  • Accountability is clear

The level of authorisation should reflect the risk and impact of the change.

4. Communicate Changes to Relevant Parties

Relevant internal and external parties should be informed of changes where appropriate, including:

  • System owners
  • Operational teams
  • Support functions
  • Suppliers or service providers

Poor communication often causes more disruption than the change itself.

5. Test Changes Before Implementation

Testing helps confirm that changes:

  • Work as intended
  • Do not introduce new vulnerabilities
  • Do not negatively affect other systems

Testing should be performed in a controlled environment where possible and aligns closely with Annex A 8.29.

6. Implement Changes in a Controlled Manner

Changes should be implemented following agreed procedures that consider:

  • Timing and scheduling
  • Rollout approach
  • Impact on availability

Controlled implementation reduces the likelihood of service disruption.

7. Maintain Rollback and Contingency Arrangements

For changes with potential impact, organisations should consider:

  • Rollback or fallback procedures
  • Emergency response arrangements
  • Dependencies on continuity and recovery plans

Being able to reverse a change quickly often limits incident impact.

8. Record and Maintain Change Information

Records should be maintained to show:

  • What was changed
  • Why the change was made
  • Who authorised and implemented it
  • When it was applied
  • Outcomes and issues identified

Change records support audit, investigation, and learning.

9. Update Documentation and Procedures

Following change, organisations should consider whether updates are required to:

  • Operating documentation
  • User procedures
  • Support guides

Out-of-date documentation undermines both security and operations.

10. Review Impact on Continuity and Recovery

Changes may affect:

  • ICT continuity plans
  • Backup and recovery procedures
  • Incident response arrangements

Annex A 8.32 supports reviewing and updating these arrangements to reflect the new environment.

11. Manage Emergency Changes Deliberately

Emergency changes may be unavoidable.

Where this occurs:

  • Changes should still be recorded
  • Risk should be assessed retrospectively
  • Lessons should be captured and applied

Emergency does not mean uncontrolled.

12. Automate Change Where Appropriate

Where feasible, organisations may benefit from:

  • Automated deployment
  • Standardised change workflows
  • Built-in approval and logging

Automation improves consistency but does not remove the need for governance.

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

  • Changes implemented without impact assessment
  • Assess security and operational impact before approval
  • Emergency fixes never reviewed
  • Apply retrospective review and learning
  • Changes not communicated
  • Inform affected stakeholders appropriately
  • No record of what changed
  • Maintain clear and accessible change records

Most outages are traced back to changes that were not properly managed.

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 8.32 is about introducing change without introducing unnecessary risk.

When change management is applied effectively:

  • Security controls remain intact
  • Availability becomes more predictable
  • Incidents reduce in frequency and impact
  • Accountability and assurance improve

Change is inevitable.
Chaos is not.

Annex A 8.32 ensures organisations change with control, not hope.

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