The Statement of Applicability (SoA) is the single most-scrutinised document in any ISO 27001 audit. It is a clause-6.1.3(d) deliverable that lists every Annex A control, states whether you implement it, the justification for inclusion or exclusion, and the implementation status. Auditors will spend roughly 40% of stage-1 audit time on the SoA alone.
The 2022 revision restructured controls into four themes. The total count dropped from 114 to 93 because of consolidation, plus 11 new controls were added.
Eleven controls are entirely new in the 2022 revision. If you are migrating from a 2013-era SoA, these are the ones auditors will check first because they are obvious omissions.
A justification of "not applicable — no cloud usage" will be rejected if auditors find your team uses Microsoft 365. Justifications must be evidence-backed, dated, and reviewed annually.
Our SoA template is a structured XLSX with all 93 Annex A controls, pre-filled implementation guidance for typical SME stacks (Microsoft 365 + Bitdefender + Azure AD), and a mapping to common related frameworks (NIS2, GDPR, SOC 2). It cuts SoA preparation from 80 hours to roughly 16 hours.
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