ISMS Statement of Applicability Template

Introduction

Information security is rapidly becoming a business necessity in this world created by the digital advancements. Cyber threats and vulnerabilities are evolving today at a speed of light, thus demanding good frameworks from all organizations regardless of size, background and industry to protect their information assets.That's where the Information Security Management System (ISMS) and Statement of Applicability (SOA) come in for the rescue. The ISO 27001 Statement Of Accountability example is one of the critical documents that has a major role in risk assessment, security controls applicable to the organization based on the risks identified, assessed and their impact on the organization is measured. ISO 27001 has updated its controls as per the 2022 latest update and currently there are 93 controls. Organizations shall use ISO 27001 statement of applicability template to record and justify out of total 93 controls as per the latest 2022 update, how many of these are applicable to them. And this decision on selecting the right control for the right information risks identified should be based on the research done to the organization’s assets and their exposure towards the cyber attacks or potential information security breaches.

What is the ISMS Statement Of Applicability?

At the core of Statement Of Applicability (SoA), it is a comprehensive document detailing about the Annex A Controls from ISO 27001 standard for your organization. It consists of risk treatment measures or controls, their implementation statuses, and justification for their inclusion or exclusion in the ISMS implementation process.

Statement of Applicability acts as a bridge between your risk assessment and risk treatment measures identified by ISO 27001 consultants or subject matter experts (internal or external) backed by detailed gap analysis, ISMS maturity assessment and risk exposure extent in terms of potential possibilities of information security breach. 

Key Elements or Contents of Statement of Applicability Template

• Controls Applicable List: As discussed in the above introduction and the definition of SoA, its fundamentals are based on recording the controls or risk treatment measures which are suggested by Subject Matter Experts, for the organization.
  
  As we know from the current update on controls as per 2022, there are 93 controls listed. But not all the controls are mandatory for implementation and not all the controls are applicable to all the organizations either. Hence control selection is purely based on the risks identified and risk assessment report. As every business is unique in its own operations, so are the risks and controls. 
  
  
• Controls Implementation Status: Once the controls are chosen as risk treatment measures, the next step would be implementing them. The controls implementation would be involved in creating a specific policy by adding the necessary technicals in terms of tackling the risks and vulnerabilities. Ex: Creating a separate policy for “Threat Intelligence Policy” with all the necessary details like threat intelligence lifecycle, threat mitigation and response etc. This is advisable as per Annex A Control 5.7 under Organizational Controls category. 
  
  
• Justification: This section in the SoA template provides space for adding justifications or explanations regarding the selection of a list of controls to be implemented. Technically, the details about inclusions and exclusions of controls are discussed here. 
  
  
• Alignment with Risks: A brief description about how the selected controls are addressing the identified risks is mentioned in this section of the SoA document. And a reality check shall be included to verify if the suggested controls are as per the ISO 27001:2022 regulatory guidelines. 
  
  
• Audit Readiness: Auditing is the mandatory and critical phase in the ISO 27001 certification process. As a result, every company aspiring for certification, should be recording the details of controls in the Statement of Applicability template. This aids in ensuring the audit readiness for the organization. Also, the Statement of Applicability document is mandatory as per the ISO 27001 regulatory guidelines.

Importance of Statement of Applicability 

• Audit Readiness and Compliance:  As mentioned in the above audit readiness point, SoA is one of the mandatory documents for ISO 27001 certification. Auditors typically rely on this document considering it as a centralized repository for verifying the security controls and their effectiveness. If the SoA is not prepared well by following the regulatory requirements of ISMS standard, it’s impossible for a company to get ISO 27001 certification.
   
• Risk Management: The SoA will make it possible for the risk management strategy to be holistic and effective because every individual control is mapped to specific risks. It also provides a clear view of how your organization will respond to vulnerabilities and adapt defensive mechanisms to those identified threats. 
  
  
• Stakeholder Trust: Transparency is the key to build trust with clients, partners, and stakeholders. Organizations getting through the ISO 27001 certification process will have a competitive advantage in the market. A well drafted SoA reassures the stakeholders that your organization has taken information security seriously and is proactively involved in managing the risks identified as per ISO 27001 standard. 
  
  
• Operational Efficiency: The SoA acts as a quick reference guide for employees and management, by clarifying which controls are in place for the risk treatment plan and why they have been chosen by the consultants or subject matter experts. This also helps in streamlining the continuous improvement process and decision making. 

Role of Statement of Applicability in ISO 27001 Framework

• Connecting Risk Assessment and Control Implementation: The SoA is the document which blends theory and practice. After conducting risk assessment, organizations identify which of the total 93 controls (as per latest 2022 update) are necessary for mitigating their unique identified risks. The SoA documents these decisions, ensuring that every control is justified and aligned with the organization's risk profile. 
  
  
• Ensure Strategic Alignment: A properly built and maintained SoA provides the confidence and acts as a justifiable document in aligning security controls with business objectives. This ensures that information security is not just a technical concern but also a strategic priority. Alignment of organizations towards ISMS standard by the medium of SoA supports operational efficiency and helps organizations adapt to changing business environments.  

Step-by-Step Guide To Create An Effective Statement of Applicability Document: 

• Conduct a Comprehensive Risk Assessment: By initiating the identification of all information assets and evaluating their potential threats and vulnerabilities, SoA provides information about the controls being implemented in the organization as per the ISMS standard. 
  
  
• Choose Relevant Annex A Controls: As per the latest 2022 update, Annex A now has 93 controls for ISO 27001 standard. So, determining which controls are applicable based on the risk identification and risk assessment and documenting them in an organized format which aligns to the ISO 27001 standard guidelines, SoA acts as a prime document for this. 
  
  
• Document Control Applicability and Status:

  • Applicability: Is the control relevant to your organization? Is it backed up by a proper risk identification and risk assessment report? These are the questions to be answered by the implementor or a consultant within the organization. 

  • Implementation Status: Is the selected list of controls implemented? Yes/In progress/No. This status check gives clarity about the controls implementation as a part of the whole ISO standard certification process.

  • Justification: Provide a clear explanation for inclusion or exclusion of the specific controls. As there are 93 controls in the 2022 update, it is advisable to provide details on choosing and dropping the controls. 

  • Alignment with Treatment Plans for Risks: The Statement of Applicability should be in line with the risk treatment plan, ensuring that every control is linked with a specific risk or regulatory requirement.

  • Regular Review and Revision: The SoA is expected to be a dynamic document. It must be subject to regular reviewing and updating to capture changes to risk environments, business objectives, and possibly the regulatory landscape.

  • Stakeholder Engagement: Stakeholders in different departments who understand their various roles in the SoA should be included in its development based on organizational risks and controls.
    

Best Practice for a Good Statement of Applicability

• Be Clear and Concise: Control choices and justifications should seriously consider using simple language to present them.

• Maintain Traceability: Specify the risk and business objectives that each control addresses.

• Leverage Technology: Fully utilize automation tools in the streamlining of documentation and updates.

• Encourage Continuous Improvement: Review and refine your SoA regularly to stay current with the changing nature of threats and changes within your organization.

• Ensure Audit Ready: Keep updated and easily retrievable documentation for auditors.

• Promote Transparency: Contain in the documentation enough reasons for each control to engender stakeholder confidence.

Common Hurdles and the Possible Solutions

• Overlooked Key Controls

Solution: All 93 Annex A controls must be reviewed and affirmed with the consultation of specialists to cover all loopholes.

• Faint Justifications

Solution: Allow for justifications that are deeper into business reasons for the inclusion or exclusion of controls—no vague stuff here.

• Rare Updates

Solution: Reviews to be scheduled regularly, at least once a year or after a significant update within the organization, to keep the SoA up-to-date.

• Lack of Stakeholder Involvement

Solution: Include people from IT, compliance, HR, and other relevant departments in the SoA drafting process.

Strategic Benefits of A Soundly Crafted SoA: 

Statement of Applicability brings not only value to one's compliance management but transcends from that:

• Better Security Posture: Real-world risk controls make the organization much more secure against threats. As there is a rapid growth towards technological and software advancements, the data of business is inevitably stored in cloud databases. Could be a private cloud or a public, hence controls protecting the information on cloud storage are advisable as best practices for information security management systems. 

• Competitive Advantage: ISO 27001 will greatly distinguish your business as it carries robust ground with an equally good SoA. As today’s businesses are aiming to expand their wings at a global level, ISO 27001 certification gives a strong boost to the companies to enter into the global village and keep their stakeholders' trust intact. This provides added leverage to competition in overseas markets. 

• Regulatory Compliance: An attestation to international standards as well as legal requirements. To achieve the global recognition and meet the standards regulatory requirements, SoA acts as a foundational document as it is the outcome of gap analysis, risk assessment and risk treatment towards ISO 27001 standard guidelines. 

• Illegible Operations: Clear and easy access for employees in efficient operations and decision making.

Sample Table: SoA Controls Mapping (For Reference)

Annex A Control	Applicability	Implementation Status	Justification (Summary)
A.5.1 Information Security Policies	Yes	Implemented	Addresses the information security policies framework needs
A.6.1 Screening	Yes	Planned	Aligns with the hiring process of employees.
A.7.1 Physical security perimeters	Yes	Implemented	Defines and protects the areas containing information and associated assets.
A.7.11 Supporting Utilities	No	Not Applicable	Not applicable as per industrial standards.

 

Frequently Asked Questions (FAQ) 

• What is the difference between SoA and risk treatment plan? 

A risk treatment plan is a plan that outlines how specific risks are going to be addressed; the SoA, on the other hand, is a documentation detailing which controls are selected for implementing those treatments and reasons for selection. 

• Is the SoA just for the bigger organizations? 

The SoA is necessary for these organizations of all possible sizes wanting to get ISO 27001 certification or otherwise to boost their information security management. 

• How often should the SoA be updated? 

Best practice is to review and update the SoA at least annually and whenever there are significant changes to your risk environment or business operations. 

• What happens if a control is an exclusion? 

Exclusions of controls must be justified properly. In the absence of this justification, it may lead to nonconformity during audits.

Conclusion

The ISMS Statement of Applicability is not just a compliance document—it’s a strategic asset that can elevate your organization’s security, build stakeholder trust, and unlock new business opportunities. By understanding its purpose, mastering its creation, and keeping it up to date, you position your organization for long-term success in a dynamic threat landscape.

Remember: A well-crafted SoA is the cornerstone of a resilient, audit-ready, and future-proof information security management system