Identity Controls for ISO 27001
ISO/IEC 27001 is the international standard for information security management. It does not prescribe products, but its Annex A controls lean heavily on identity, and auditors will expect you to show how access is granted, reviewed, and removed. This maps the identity-relevant controls to what you actually build.
What ISO 27001 expects of identity
The 2022 revision groups controls into themes. The identity-relevant ones include access control, identity management, authentication information, and privileged access:
- Access control (A.5.15): a documented policy and least-privilege enforcement.
- Identity management (A.5.16): a managed lifecycle for every identity, human and non-human.
- Authentication information (A.5.17): secure handling of credentials, pushing toward MFA and passwordless.
- Access rights (A.5.18): provisioning, review, and prompt removal, the joiner-mover-leaver lifecycle.
- Privileged access (A.8.2): restricted, monitored, and time-bound.
What good looks like
- SSO and MFA across in-scope systems, with phishing-resistant factors for privileged users.
- Automated provisioning and deprovisioning via SCIM, so leavers lose access promptly.
- Periodic access reviews with evidence, typically through IGA.
- PAM for privileged accounts with session logging.
Common pitfalls
- Access reviews that happen but are not evidenced; auditors want the artifact.
- Orphaned and service accounts outside the lifecycle.
- Privileged access granted permanently rather than just in time.
Related
IAM audit preparation, SOC 2 for identity. Vendors: IGA, PAM.
Mapping identity to Annex A
The identity-relevant controls in the 2022 Annex A cluster tightly, and mapping them explicitly saves argument during certification:
- A.5.15 Access control and A.5.18 Access rights: policy, provisioning, review, and removal. This is where access certification evidence lands.
- A.5.16 Identity management: unique identities, lifecycle, and the handling of non-human identities.
- A.5.17 Authentication information: credential issuance, MFA, and secure recovery.
- A.8.2 Privileged access rights: allocation, review, and restriction of elevated access.
- A.8.5 Secure authentication and A.8.15 Logging: the technical implementation and its audit trail.
What certification actually tests
Auditors test operation, not intent. The recurring findings in identity are predictable: access reviews completed but with no revocations, leavers removed from single sign-on while local and vendor accounts stayed live, privileged rights granted for a project and never withdrawn, and an MFA exemption list that has grown without review.
The corresponding evidence to keep is equally predictable. Review campaigns with revocation counts, a leaver reconciliation across systems outside SSO, a standing-privilege count trending down, and a dated exemption register with justification per entry.
Where the ISMS scope bites
ISO 27001 lets you scope the ISMS, and identity systems have a way of straddling the boundary. If your identity provider authenticates access to both in-scope and out-of-scope systems, it is in scope, and so are its administrators. Decide that early rather than during the audit, and treat the identity provider itself as tier-zero infrastructure. See what is IGA and zero standing privileges.
Where to start
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