Information Security Incident Management Planning and Preparation ISO 27001: Complete Guide (A.5.24)

Introduction

Information Security Incident Management Planning and Preparation is a critical ISO 27001 control that ensures organizations are proactively prepared to detect, respond to, and recover from security incidents. Defined under ISO 27001:2022 Annex A.5.24, this control focuses on establishing structured planning, defined responsibilities, and response procedures before incidents occur.

In today’s threat landscape, incidents are inevitable. Ransomware, phishing, insider threats, and system breaches can affect organizations of any size. Without preparation, organizations often face delayed response times, uncoordinated decision-making, increased operational impact, reputational harm, and regulatory exposure. This makes incident planning not only a compliance requirement, but also a business-critical capability.

Platforms such as Comply Agent can help organizations operationalize this control by linking incident response plans, training records, and audit evidence into a centralized compliance framework.

Basic Information

From the provided control structure, this control is defined as follows:

• Control ID: UC-IN-024
• Category: Incident Response
• Subcategory: Planning and Preparation

The control description emphasizes the need to develop an Incident Response Plan (IRP) that includes roles, escalation procedures, and communication protocols. The objective is to establish a structured approach for anticipating, detecting, responding to, and recovering from incidents while minimizing business impact and supporting continuity.

Organizations that do not prepare adequately often experience:

• Delayed response times
• Uncoordinated actions across teams
• Increased financial and reputational damage
• Regulatory non-compliance

This is why ISO 27001 A.5.24 is a foundational governance control. It ensures that when incidents occur, the organization is not reacting blindly, but following a defined, tested, and accountable response model.

Implementation & Guidance

The implementation guidance highlights the need to develop a comprehensive incident response plan ISO 27001 framework and test it regularly through simulations, exercises, and role-based readiness activities.

Key Implementation Requirements

• Develop a formal Incident Response Plan (IRP)
• Define roles and responsibilities
• Establish escalation procedures
• Conduct regular testing and simulations
• Maintain training and awareness programs

Step-by-Step Implementation Approach

1. Develop the Incident Response Plan (IRP)
   The IRP should define:
   • Incident classification criteria such as low, medium, and high severity
   • Response procedures for different incident types
   • Communication and notification protocols
   • Escalation paths and decision points
2. Define Roles and Responsibilities
   Establish a dedicated Incident Response Team (IRT), which may include:
   • Incident Manager
   • Technical responders
   • Communications lead
   • Legal and compliance representatives
3. Establish Escalation Procedures
   Define:
   • When incidents must be escalated
   • Who approves escalation decisions
   • External reporting and notification requirements
4. Conduct Simulation Exercises
   Regularly test the plan through:
   • Tabletop exercises
   • Technical simulations
   • Red team and blue team scenarios
5. Provide Training and Awareness
   Ensure employees:
   • Understand incident reporting procedures
   • Recognize potential incidents
   • Follow escalation and communication protocols
6. Maintain Continuous Improvement
   After each incident or exercise:
   • Conduct post-incident or post-exercise reviews
   • Update the IRP
   • Address gaps and lessons learned

Consultant Insight

A common failure is having a documented IRP that is never tested. Auditors do not only want to see a policy document. They typically expect evidence of real testing, staff participation, review outcomes, and continuous improvement. Strong IRP implementation means the plan is living, reviewed, exercised, and improved over time.

With Comply Agent, organizations can track IRP versions, simulation results, training records, and follow-up actions in a single structured compliance environment.

Operational Details

Key Operational Characteristics

• Frequency: Quarterly
• Review Cycle: Quarterly
• Owner Role: CISO
• Automation Score: 70%

Incident planning operates as a continuous readiness process rather than a one-time documentation exercise. The plan must be maintained, roles must remain current, staff must be trained, and exercises must validate whether the organization can respond effectively under pressure.

How the Control Operates

• The IRP is maintained and updated
• Roles and responsibilities are reviewed and validated
• Training sessions and awareness activities are conducted
• Exercises and simulations are planned and executed
• Lessons learned are captured and fed back into the process

Responsibilities

CISO

• Owns the overall incident management strategy
• Provides governance and executive oversight

Incident Response Team

• Executes response activities during incidents
• Supports testing, simulations, and operational readiness

Compliance Team

• Ensures alignment with ISO 27001 requirements
• Supports evidence collection and audit readiness

Automation Perspective

While incident planning itself is largely manual and governance-driven, automation can support important operational elements such as incident tracking systems, notification workflows, evidence capture, and document review reminders. This helps strengthen incident management compliance without removing the need for human decision-making and preparedness.

Compliance & Risk Management

This control is classified as an Administrative control within the Operational Resilience domain.

Risks of Poor Incident Planning

• Delayed incident detection and escalation
• Ineffective or inconsistent response actions
• Prolonged system downtime and disruption
• Regulatory violations and reporting failures
• Weak organizational resilience during security events

Compliance Impact

Failure to implement this control can lead to:

• Inability to demonstrate preparedness
• ISO 27001 audit nonconformities
• Weak incident response capability
• Poor evidence of governance and readiness

Audit Implications

Auditors will usually verify:

• The existence of a formal IRP
• Defined roles and responsibilities
• Documented escalation procedures
• Evidence of testing and simulations
• Training and awareness records

A control marked as not started represents a major compliance gap because incident planning is expected to be established before an incident occurs, not during one.

Framework Mappings

Key Mappings

• ISO  Incident Management Planning and Preparation
• SOC 2: CC
• Article 33 (Breach Notification)
• DORA: Articles 
• A.5.25 Incident Response, A.5.26 Incident Assessment, A.5.27 Incident Response Learning, A.5.28 Evidence Collection

Why This Matters

Incident management is a common requirement across security, privacy, and operational resilience frameworks. A strong planning and preparation control can therefore support multiple obligations at once, reducing duplicated compliance effort and improving consistency of response.

Using Comply Agent, organizations can map incident management controls across frameworks and maintain unified tracking of evidence, ownership, and readiness activities.

Evidence Library

Key Evidence Types

1. I******* Plan (IRP)
   A documented plan covering response procedures, roles, communications, and escalation paths.
2. IR Team Roster and Contact List
   A current list of responsible personnel and contact details to enable rapid coordination during incidents.
3. E*************n
   Defined escalation paths, communication rules, and decision-making procedures for incident handling.

Additional Expected Evidence

• Simulation and exercise records
• Training attendance logs
• Post-incident or post-exercise review reports
• Plan review and update history

Why Evidence Matters

Auditors rely on evidence to confirm that:

• Preparedness measures exist
• Roles are clearly defined
• Procedures are actionable and current
• Response capability has been tested

A structured evidence library makes it easier to demonstrate that the organization is not only planning for incidents on paper, but is actively maintaining operational readiness.

Conclusion

Information Security Incident Management Planning and Preparation (ISO 27001 A.5.24) is essential for building a proactive and resilient security posture. It ensures organizations are prepared with structured plans, defined responsibilities, tested processes, and trained teams before an incident occurs.

Organizations that implement this control effectively benefit from:

• Faster and more coordinated incident response
• Reduced business impact during security events
• Improved operational resilience
• Stronger audit readiness

By leveraging structured platforms such as Comply Agent, organizations can centralize incident response planning, track evidence, manage updates, and maintain continuous compliance visibility.

FAQs

1. What is Incident Management Planning in ISO 27001?

It is a control that ensures organizations prepare structured plans, responsibilities, and procedures to detect, respond to, and recover from security incidents.

2. Which ISO clause covers this control?

ISO 27001:2022 Annex A.5.24 covers incident management planning and preparation.

3. What evidence is required for audits?

Typical evidence includes IRP documents, incident team rosters, escalation procedures, training records, and simulation or exercise results.

4. How often should the IRP be tested?

It should be tested regularly, typically at least annually, and also through periodic tabletop exercises or technical simulations based on risk and organizational needs.

5. What are common audit findings?

Common issues include an untested IRP, unclear roles, missing escalation procedures, outdated contact lists, and lack of training or exercise evidence.

6. How can Comply Agent help?

Comply Agent can centralize IRP documentation, track testing evidence, manage ownership, and improve overall audit readiness and compliance visibility.