Skip to content
Sovereign SecureSovereign Secure

Free ISO 27001 template

ISO 27001 Statement of Applicability: Template and Worked Example

The required columns, a worked example and a free template covering all 93 Annex A controls, so your Statement of Applicability matches your risk assessment before the auditor reads it. Download it as a spreadsheet (.xlsx), free and with no sign-up.

Prefer to talk? Call +44 161 523 5276

  • Free .xlsx template with all 93 ISO/IEC 27001:2022 Annex A controls
  • Worked example with inclusion and exclusion justifications
  • The SoA problems that lead to audit findings
  • From an ISO 27001-certified UK consultancy

The short answer

A Statement of Applicability (SoA) is the ISO 27001 document, required by clause 6.1.3 d), that lists every control your ISMS needs, why each is included and whether it is implemented, and justifies every Annex A control you exclude. Under ISO/IEC 27001:2022 it must account for all 93 Annex A controls, plus any extra controls you add.

On this page
  1. What is a Statement of Applicability in ISO 27001?
  2. Why do auditors start with the SoA?
  3. What must an ISO 27001 SoA include?
  4. Statement of Applicability example: a completed SoA
  5. Can you exclude Annex A controls?
  6. How does the SoA link to the risk assessment and treatment plan?
  7. What SoA problems lead to audit findings?
  8. The Statement of Applicability template
  9. Why Sovereign Secure
  10. Get the SoA template or a review

The ISO 27001 Statement of Applicability (SoA) is the document that lists every control your information security management system (ISMS) needs, explains why each one is included, states whether it is implemented and justifies every Annex A control you leave out. Clause 6.1.3 d) of ISO/IEC 27001:2022 makes it mandatory, and it is one of the first documents a certification auditor reads.

This page covers the required columns, a worked example, how to justify exclusions, the problems that lead to audit findings and a template for all 93 Annex A controls, which you can also download as a spreadsheet.

What is a Statement of Applicability in ISO 27001?

It is the record of your control decisions. Your risk assessment identifies the risks; the SoA shows which controls you chose to treat them, and how those choices compare with the 93 controls in Annex A.

Clause 6.1.3 d) requires the SoA to contain four things:

  1. The necessary controls, whether taken from Annex A or from elsewhere.
  2. The justification for including each one.
  3. Whether each necessary control is implemented or not.
  4. The justification for excluding any Annex A control.

Two consequences follow. Every one of the 93 Annex A controls must appear, either included or excluded with a reason. And controls you add from other sources, such as PCI DSS, a customer contract or your own design, belong in the SoA too, because the standard says Annex A is not an exhaustive list.

Why do auditors start with the SoA?

Because it is the map of your ISMS. At the Stage 1 audit, the certification body reads the SoA alongside your scope, risk assessment and risk treatment plan to check that the design hangs together. At Stage 2, auditors sample controls you marked as implemented and ask for evidence that they operate. Your certificate normally references the SoA version it was issued against, which is why customers ask to see it during due diligence. Our guide to the ISO 27001 certification audit explains both stages.

What must an ISO 27001 SoA include?

The first five columns below come straight from clause 6.1.3 d). The rest are good practice that makes the SoA easier to audit and maintain.

Column Required? What to write
Control reference and name Yes Annex A number and title, such as 5.23 Information security for use of cloud services, or your own reference for an additional control
Applicable Yes Yes or no
Justification for inclusion Yes The risks treated (by risk ID), plus any legal, regulatory or contractual requirement
Implementation status Yes Whether the control is implemented; most SoAs record implemented, partly implemented or planned
Justification for exclusion Yes, for excluded Annex A controls A specific reason why no risk or requirement calls for the control
How it is implemented Good practice The policy, procedure, system or service that delivers the control
Evidence reference Good practice Where an auditor will find the records
Control owner Good practice A named role, not “IT”
Version and approval Good practice Version number, review date and approver

Many organisations tag the reason for inclusion with a short code: R for risk treatment, L for legal or regulatory, C for contractual and B for business requirement. The standard does not ask for codes, but they make a long SoA quick to read.

Statement of Applicability example: a completed SoA

This Statement of Applicability example is an illustrative extract for a fictional 40-person UK software company, showing included controls, exclusions with reasons and an additional control. It has no office, its staff work from home, it hosts its product in a public cloud and it writes its own code. Risk IDs refer to its risk register.

Control Applicable Justification Status
5.7 Threat intelligence Yes R-03 phishing, R-08 ransomware Partly implemented
5.23 Information security for use of cloud services Yes R-02 cloud misconfiguration; customer contracts (C) Implemented
6.7 Remote working Yes R-05 lost or stolen laptops; all staff home-based Implemented
7.1 Physical security perimeters No No company premises. Hosted systems sit in a public cloud whose physical security is assured through supplier controls 5.19 to 5.23 Not applicable
7.9 Security of assets off-premises Yes R-05; all equipment is used off-premises Implemented
8.11 Data masking Yes R-09 customer data copied into test environments Planned, in the risk treatment plan
8.28 Secure coding Yes R-06 vulnerabilities in our own application Implemented
8.30 Outsourced development No All development is done by employees and none is contracted out. Reviewed at each risk assessment Not applicable
ADD-01 Annual Cyber Essentials Plus certification Yes Contractual requirement from public sector customers (C) Implemented

Three things to notice:

  • Planned is not excluded. Data masking (8.11) is applicable but not yet in place. It stays in the SoA as planned, with an owner and date in the risk treatment plan.
  • Exclusions can be tested. An auditor can confirm there is no office and no development contract. If either changes, the exclusion falls away.
  • Additional controls sit alongside Annex A. ADD-01 comes from a contract, not from Annex A, and is tracked the same way.

Can you exclude Annex A controls?

Yes. You can exclude any Annex A control that no identified risk, legal, regulatory or contractual requirement calls for, provided the SoA records why. You cannot exclude any of the ISO 27001 requirements in clauses 4 to 10, which apply to every ISMS.

The test is whether an auditor could check the justification against reality:

Weak justification Stronger justification
“Not applicable to our business” (8.28 Secure coding) “No software is written in-house or by contractors; all business applications are SaaS. Reviewed at each risk assessment.”
“Handled by our cloud provider” (7.1 Physical security perimeters) “No company premises. Physical security of hosted systems is assured through supplier controls 5.19 to 5.23, including review of the provider’s ISO 27001 certificate.”
“Too expensive” (any control) “Risk R-12 was accepted by its risk owner on [date] under our risk acceptance criteria; no control is needed.”

Three areas need care:

  • Physical controls in a remote company. Perimeter and entry controls (7.1 to 7.4) may not apply, but 7.7 clear desk and clear screen, 7.9 off-premises assets, 7.10 storage media and 7.14 secure disposal or re-use of equipment usually still do.
  • Development controls (8.25 to 8.31). Decide them one by one. Some, such as 8.26 application security requirements, also cover applications you acquire, and 8.30 applies the moment a contractor builds anything for you.
  • Cloud services (5.23). Almost every organisation that uses Microsoft 365, Google Workspace or a hosted platform needs it.

Clause 6.1.3 sets the order, and the SoA comes out of your risk treatment decisions rather than before them.

Step Clause Output
Identify, analyse and evaluate risks 6.1.2 Risk register with named risk owners
Choose how to treat each risk 6.1.3 a) A treatment decision for each risk
Decide the controls needed 6.1.3 b) List of necessary controls
Compare them with Annex A 6.1.3 c) Confirmation that no necessary control has been missed
Produce the SoA 6.1.3 d) Statement of Applicability
Plan the treatment 6.1.3 e) Risk treatment plan with owners and dates
Approve 6.1.3 f) Risk owners approve the plan and accept the residual risk

Keep the link traceable both ways: every treated risk points to controls in the SoA, and every applicable control points back to at least one risk or named requirement. Filling in an SoA template first and inventing reasons afterwards produces a list of controls with no risks behind them, and auditors spot it quickly. Our guide to ISO 27001 risk assessment covers the method and the register.

What SoA problems lead to audit findings?

These are the issues that typically turn into nonconformities or observations:

  • SoA and risk treatment plan disagree. A control is marked applicable with no risk behind it, or a treatment relies on a control the SoA excludes.
  • Copied justifications. The same sentence against dozens of controls, often straight from a template.
  • Exclusions contradicted by reality. 5.23 excluded while the company runs on Microsoft 365, or 8.30 excluded while a contractor builds the website.
  • “Implemented” without evidence. At Stage 2 the auditor asks for records and there are none.
  • Still on the 2013 structure. References to A.5 to A.18 and 114 controls, although the transition to the 2022 edition ended on 31 October 2025.
  • No version control or approval. No owner, date or sign-off, or no update after a change of scope.
  • Missing additional controls. Contractual or PCI DSS requirements handled outside the ISMS and absent from the SoA.

For a wider pre-audit check, use our ISO 27001 checklist.

The Statement of Applicability template

Download the free SoA template (Excel, .xlsx), or copy the layout below into your own spreadsheet, with one row for each of the 93 Annex A controls followed by rows for any additional controls. The controls run 5.1 to 5.37 (organisational), 6.1 to 6.8 (people), 7.1 to 7.14 (physical) and 8.1 to 8.34 (technological); our guide to ISO 27001 Annex A controls explains each one.

Ref Control Applicable Reason (R, L, C, B) Justification and risk IDs Status Owner and evidence
5.1 Policies for information security
5.2 Information security roles and responsibilities
… (one row per control)
8.34 Protection of information systems during audit testing
ADD-01 [Additional control]

Above the table, add a header block with the document owner, version, approval date and the ISMS scope the SoA covers. Then:

  1. Complete the risk assessment and treatment decisions first.
  2. Mark each control applicable or not, citing risk IDs or a named requirement.
  3. Record honest implementation status. “Planned” is acceptable when the risk treatment plan gives an owner and a date.
  4. Have the SoA approved, then review it whenever the risk assessment, scope or services change.

The download does the layout for you. It lists all 93 controls by number, title and theme, with drop-down lists for Applicable and Implementation status and columns for the reason code, linked risk IDs, justification, how each control is implemented, evidence and owner. It also has the header block, ten rows for additional controls, a completeness check on every row, the worked example above and a summary sheet that counts applicability and status by theme. It is free to use and adapt within your organisation.

A template saves layout time; the decisions in it must still come from your own risk assessment.

Why Sovereign Secure

  • ISO 27001 certified ourselves, so we maintain our own SoA and go through surveillance audits too.
  • An SoA built from your risks, as part of our ISO 27001 consultancy. Certification audits are carried out by an independent certification body, our partner MQA International.
  • One control set for several schemes. As a PCI SSC Qualified Security Assessor (QSA) company and an IASME-licensed Cyber Essentials certification body, we bring PCI DSS and Cyber Essentials requirements into your SoA.
  • Testing evidence for 8.8 and 8.29 through ISO 27001 penetration testing.
  • UK company since 2012, headquartered in Accrington, Lancashire (Companies House 08334453).

Get the SoA template or a review

Download the free SoA template (.xlsx). For help completing it, use the form below, which is already set to ISO 27001. If you already have an SoA, an ISO 27001 gap analysis checks it against your risk register and evidence before the certification auditor does. Or call +44 161 523 5276.

Last reviewed October 2026 by the Sovereign Secure assessment team.

Trusted by banks, payment providers and global brands

  • Accor
  • Fiserv
  • JCPenney
  • Ticketmaster
  • Nitecrest
  • Cashplus
  • Ahli United Bank
  • Kuwait Finance House
  • AYA Bank
  • Bank of Palestine
  • Liquid Pay
  • DataFlow Group
  • Wilmington
  • The Growth Company
  • Wahyukart

FAQ

Frequently asked questions

Can't find your answer? Call us on +44 161 523 5276 or send us a message.

What is a Statement of Applicability?

It is the ISO 27001 document that records your control decisions: which controls the ISMS needs, why, whether each is implemented, and why any Annex A control has been excluded. Clause 6.1.3 d) of ISO/IEC 27001:2022 requires it.

Is the Statement of Applicability mandatory?

Yes. Clause 6.1.3 d) requires every ISO 27001 ISMS to produce one, and the certification body reviews it at the Stage 1 audit. Without an SoA you cannot be certified.

Can you exclude Annex A controls?

Yes, if no identified risk, legal, regulatory or contractual requirement calls for the control, and you record a specific justification in the SoA. You cannot exclude any requirement in clauses 4 to 10.

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

The SoA lists which controls apply, why, and their status. The risk treatment plan (clause 6.1.3 e) sets out how and when the remaining work will be done, by whom, and is approved by the risk owners. The two must agree; see our guide to ISO 27001 risk assessment.

How often should the SoA be updated?

Whenever the risk assessment, ISMS scope or services change, and at least once a year as good practice, usually ahead of the management review. Keep each approved version, because your certificate usually references the version it was issued against.

Do we have to share our SoA with customers?

No, the standard does not require it. Customers often ask for it, though, because the certificate alone does not show which controls are in place, and many organisations share it under a non-disclosure agreement.

Can we keep our ISO 27001:2013 SoA?

No. The 2013 edition had 114 controls in 14 domains; the 2022 edition has 93 in four themes, and the transition period ended on 31 October 2025. Rebuild the SoA on the 2022 control list; our guide to ISO 27001 Annex A controls lists them.

Can I get the SoA template as a spreadsheet?

Yes. Download the free SoA template (Excel .xlsx, no sign-up): it lists all 93 Annex A controls with drop-down lists for applicability and status, plus rows for additional controls, the worked example and a summary sheet that counts your progress. If you want help completing it, use the form on this page.

Free consultation

Talk to an assessor

We aim to reply within one working day, and send a fixed quote once your scope is confirmed.

  • PCI SSC-approved QSA, QPA, CPSA, P2PE and 3DS assessors
  • IASME-licensed Cyber Essentials certification body
  • Clients across the UK, US, Europe, Middle East and Asia since 2012

“We are satisfied with the quality of work delivered by Sovereign Secure and would happily recommend them to any company that requires consultancy and guidance in obtaining their ISO 27001 certification.”

Edmund How, Managing Director, Onesecure Asia. Read the full testimonial

By sending this form you agree to us contacting you about your enquiry. See our privacy policy.

We aim to reply within one working day. The first consultation is free.