Why run an ISO 27001 gap analysis now

The transition is over. Under IAF MD 26, organizations had “36 months from the last day of publication month of ISO/IEC 27001:2022 (i.e. 31 October 2025)” to move, and “All certifications based on ISO/IEC 27001:2013 shall expire or be withdrawn at the end of the transition period” (IAF MD 26). Any organization still running 2013-era controls, or preparing for first certification, needs a gap analysis against the 2022 edition.

Demand keeps growing. The ISO Survey 2024 reports 96,709 ISO/IEC 27001 certificates, up from 47,291 the year before (ISO Survey 2024 infographic). Part of that jump likely reflects a change in data collection: ISO now compiles the survey from IAF CertSearch (ISO).

For how ISO 27001 certification compares with a SOC 2 examination, see ISO 27001 vs SOC 2 Assessment: Choosing a Security Compliance Assessment.

What you are measuring against

PartContents
Clauses 4–10 (mandatory)Context, leadership, planning (including new 6.3 planning for changes), support, operation, performance evaluation, improvement
Annex A (93 controls)Organizational (37), People (8), Physical (14), Technological (34) (Secureframe)
Amendment 1:2024”Climate action changes,” published February 23, 2024 (ISO)

The 2022 edition replaced 114 controls with 93, and 11 controls are new (Cloud Security Alliance), including threat intelligence, cloud services security, data masking, data leakage prevention and secure coding.

Related standard to watch: ISO/IEC 42001. Published December 18, 2023, it specifies requirements for an AI management system (ISO). Organizations building AI products increasingly run 27001 and 42001 gap analyses together, and questionnaires such as SIG 2026 now map to ISO 42001.

ISO 27001:2022 gap analysis checklist

Management system (clauses 4–10)

  • 4: Scope defined, with internal and external issues and interested parties’ requirements
  • 5: Information security policy approved; roles and responsibilities assigned
  • 6.1: Risk assessment and treatment methodology defined; risk treatment plan approved
  • 6.1.3: Statement of Applicability lists all 93 Annex A controls with justification
  • 6.2: Measurable security objectives set
  • 6.3: Changes to the ISMS are planned (new in 2022)
  • 7: Resources, competence, awareness and documented information controlled
  • 8: Risk assessments and treatment carried out at planned intervals
  • 9: Monitoring, internal audit and management review performed
  • 10: Nonconformities corrected; continual improvement evidenced
  • Climate change considered in context and interested parties (Amendment 1:2024)

Annex A: new 2022 controls to check first

  • Threat intelligence
  • Information security for use of cloud services
  • ICT readiness for business continuity
  • Physical security monitoring
  • Configuration management
  • Information deletion
  • Data masking
  • Data leakage prevention
  • Monitoring activities
  • Web filtering
  • Secure coding

For each control, record

FieldExample
Control5.23 Cloud services security
StatusPartially met
EvidenceCloud security policy v2 §3; vendor review records
GapNo exit strategy for critical SaaS providers
Owner and due dateIT Security lead, Q1

What to look for in ISO 27001 gap analysis software

CapabilityWhy it mattersRed flag
Evidence linked to each controlAuditors test evidence, not checkboxesSelf-attested status with no documents
Passage-level citationsReviewers can verify in secondsScores with no source
SoA generation from assessmentKeeps SoA and reality in syncSoA maintained in a separate spreadsheet
Multi-framework mappingReuse evidence for SOC 2, NIST CSF, ISO 42001One framework only
Human review and audit trailAccountability for each judgmentAI decides status alone

Assess your ISMS documents in hours

The bulk of a gap analysis is reading: policies, procedures, risk registers and records, each checked against clauses and controls. AI evidence assessment can map your documents to ISO 27001:2022, flag controls with no supporting evidence and cite the passage behind every finding.

Try a security evidence assessment on your current policy set. AskDona shows the evidence; your team decides.

FAQ

Is ISO 27001:2013 still valid? No. Certifications to the 2013 edition expired or were withdrawn after October 31, 2025 (IAF MD 26).

How many controls are in ISO 27001:2022 Annex A? 93, in four themes: organizational, people, physical and technological (Secureframe).

What did Amendment 1:2024 change? It adds climate action changes to the standard, published February 23, 2024 (ISO).

Should we do ISO 42001 at the same time? If you build or deploy AI, a combined gap analysis saves effort, since both are management system standards (ISO).

References

All pages opened and checked by October 9, 2026.

SourceTypeDateUsed for
ISO: ISO/IEC 27001:2022Standards bodyOct 25, 2022Standard status
ISO: Amendment 1:2024Standards bodyFeb 23, 2024Climate action changes
IAF MD 26 Issue 2Accreditation bodyFeb 15, 2023Transition deadline
Secureframe: ISO 27001 controlsVendor blogUndatedAnnex A themes
CSA: ISO/IEC 27002:2022 updateIndustry bodyFeb 23, 202293 controls, 11 new
ISO Survey 2024 infographicSecondary (ISO data)Oct 2025Certificate counts
ISO: The ISO SurveyStandards body2025Method change
ISO: ISO/IEC 42001Standards bodyDec 18, 2023AI management system