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ISO 27001 Statement of ApplicabilityISO 27001 Statement of Applicability (SoA): what it is and how to write one
The Statement of Applicability is the one ISO 27001 document that every auditor reads closely. This guide explains what clause 6.1.3(d) requires, how the SoA connects to your risk assessment, how to write justifications that hold up and the mistakes that cause findings.
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What is a Statement of Applicability in ISO 27001?
The Statement of Applicability (SoA) is a mandatory ISMS document. It lists the information security controls you have determined are necessary, gives the justification for including them, states whether each is implemented, and gives the justification for excluding any Annex A control. It is the bridge between your risk assessment and the controls an auditor will test.
- Annex A is a reference list of 93 controls, not a list you must all implement. The SoA is where you record which apply and why.
- Every exclusion needs a reason. A blank or vague reason is a common audit finding.
- The SoA must follow from your risk assessment. See the requirements guide and the Annex A controls list.
How the SoA is produced from your risk work
You do not start with the SoA. You finish it last, from decisions already made.
Clause 6.1.3 also asks you to compare your determined controls with Annex A to verify that no necessary control has been omitted. Annex A is not exhaustive, so you may add controls from other sources.
What clause 6.1.3(d) requires, in plain terms
| Clause 6.1.3(d) asks for | In plain terms | What an auditor tends to look for |
|---|---|---|
| The necessary controls | Every control your risk treatment needs, from Annex A or anywhere else | A traceable link from risks to controls |
| Justification for including them | Why each control is in | A reason tied to a risk, contract or legal duty, not just that the standard lists it |
| Whether they are implemented | An honest status for each control | A status that matches what they see in practice |
| Justification for excluding any Annex A control | Why each Annex A control you left out is not needed | A specific, risk-based reason that holds up under questioning |
ISO/IEC 27001:2022 still requires the SoA. What changed in 2022 is the Annex A list it refers to: 93 controls in four themes. The 2013 transition has ended, so check that your SoA refers to the 2022 list. See the Annex A guide.
What a Statement of Applicability looks like
The standard sets what it must contain, not its layout. A spreadsheet or a table in a tool both work.
| Column | Why it is there | Source |
|---|---|---|
| Control reference and name | Identifies the control, usually from Annex A | From the standard |
| Applies or not | Records the include or exclude decision | From the standard |
| Justification | Gives the reason for inclusion or exclusion | From the standard |
| Implementation status | Says whether the control is implemented | From the standard |
| Control owner | Names who is accountable | Good practice |
| Linked risk or requirement | Shows why the control exists | Good practice |
| Evidence reference | Points the auditor to proof | Good practice |
| Version and review date | Shows the document is controlled and current | Good practice |
How to write a Statement of Applicability in 7 steps
Finish the risk assessment
Identify and rate your information security risks within your scope. The SoA needs these as its input.
Choose treatment options
Decide for each risk whether to modify, retain, avoid or share it. Controls follow from the ones you modify.
Determine the controls you need
List every control needed to treat your risks. They can come from Annex A, from another framework or from your own design.
Check against Annex A
Walk through all 93 Annex A controls. Confirm none you need has been missed, and note the ones you will not use.
Record each decision
For every control, write applies or does not apply, with a specific reason tied to a risk, a contract, a law or your scope.
Add status and owner
State whether each applicable control is implemented, in progress or planned, and name an owner and where the evidence lives.
Approve and version it
Get the risk treatment plan approved and residual risk accepted by risk owners, and put the SoA under document control. Ask your certification body who it expects to approve the SoA.
Weak and strong justifications
The reasons are where most SoAs fail. A reason should name something real.
| Situation | Weak entry | Stronger entry |
|---|---|---|
| Control included | Required by ISO 27001 | Treats risk R-04, unauthorised access to customer data |
| Control excluded | Not relevant | We do not develop software, and our scope covers only services we buy |
| Risk accepted instead | Too costly | Risk assessed as low and formally accepted by the named risk owner |
| Control implemented | Done | Implemented. Evidence: quarterly access review records |
| Control not yet in place | Left blank | In progress, in the treatment plan, owner named |
Common Statement of Applicability mistakes
- Copying a template unchanged: generic reasons do not match your risks.
- Vague exclusions: “not applicable” with no reason.
- Deleting excluded controls: keep them listed with the reason.
- No link to risk: controls that trace to nothing.
- Claiming implemented too early: the status must be true at audit.
- Scope mismatch: excluding something your scope clearly includes.
- Forgetting the 2022 list: still using the 2013 numbering.
- Never updating it: the SoA drifts away from the real ISMS.
Keeping the Statement of Applicability current
- Update it when the risk assessment, scope or controls change, and after incidents that expose a gap.
- Review it in your internal audit and management review cycle, and keep version history.
- Use the checklist to track it with the other mandatory documents, and see the guide to choosing a certification body before your audit.
ISO 27001 Statement of Applicability: questions answered
What is a Statement of Applicability in ISO 27001?
Is the Statement of Applicability mandatory?
Do I have to implement all 93 Annex A controls?
Can I use controls that are not in Annex A?
What is the difference between the SoA and the risk treatment plan?
Who approves the Statement of Applicability?
How often should I update the SoA?
Do I have to show the SoA to customers?
Can I mark a control as applicable before it is implemented?
Is there an ISO 27001 SoA template?
What changed in the SoA for ISO 27001:2022?
Do auditors check the SoA against reality?
Know what goes in your SoA? Get matched with the right provider.
Free for buyers · provider-funded introductions · Reviewed October 2026 by the ZCyberSecurity compliance team