ISO 27001:2022 Annex A 5.21 Managing Information Security In The ICT Supply Chain Explained

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Last updated Dec 8, 2025

Author: Stuart Barker | ISO 27001 Lead Auditor

ISO 27001 Managing Information Security In The ICT Supply Chain

ISO 27001 Annex A 5.21 is managing information security in your IT suppliers and means you need a process to handle information security risks of your third party suppliers, products, systems and services.

What is ICT?

ICT, or information and communications technology (or technologies), is the infrastructure and components that enable modern computing.

What is ISO 27001 Annex A 5.21?

ISO 27001 Annex A 5.21 Managing information security in the ICT supply chain is an ISO 27001 control that requires an organisation to manage the risks associated the ICT products and services supply chain.

ISO 27001 Annex A 5.21 Purpose

The purpose of ISO 27001 Annex A 5.21 is a preventive control that ensures you maintain an agreed level of information security in supplier relationships.

ISO 27001 Annex A 5.21 Definition

The ISO 27001 standard defines ISO 27001 Annex A 5.21 as:

Processes and procedures should be defined and implemented to manage the information security risks associated with the ICT products and services supply chain.

ISO 27001:2022 Annex A 5.21 Managing information security in the ICT supply chain
ISO 27001 Toolkit Business Edition
ISO 27001:2022 Toolkit
ISO 27001 Toolkit Consultant Edition
ISO 27001:2022 Toolkit Consultant Edition

How to implement ISO 27001 Annex A 5.21

We discussed above that ICT means information and communications technology and we would include cloud services in that.

When we implement we are looking to build on existing best practices for information security, project management, quality management and engineering and not to replace those practices.

You are going to have to ensure that:

  • you have information security requirements when acquiring products or services
  • your suppliers propagate your security requirements through ‘their’ supply chain if they sub contract
  • you request, and understand, of product suppliers, what software components they use
  • you request and understand product security functions and how to configure it to be secure
  • you implement monitoring and validation of security requirements in your suppliers
  • you identify and document critical products and services
  • critical components and their origin can be traced through the supply chain
  • you have assurance products are functioning as expected
  • you have assurance products meet required security levels
  • you have rules for sharing information including issues and compromises
  • you have process for managing component lifecycles, availability and associated security risks
  • you have considered alternate suppliers and how to transfer to them if needed

It is always best and goes without saying, or it should, that you will acquire your products and services from reputable sources.

Watch the ISO 27001 Annex A 5.21 Tutorial

In the video ISO 27001 Managing Information Security In The ICT Supply Chain Explained – ISO27001 Annex A 5.21 I show you how to implement it and how to pass the audit.

ISO 27001 Supplier Register Template

The ultimate ISO 27001 Supplier Register Template.

ISO27001 Third Party Supplier Register Template

ISO 27001 Supplier Policy Template

The ultimate ISO 27001 Supplier Register Template.

ISO27001 Third Party Supplier Policy Template

How to comply

To comply with ISO 27001 Annex A 5.21 you are going to implement the ‘how’ to the ‘what’ the control is expecting. In short measure you are going to

  • Implement a topic specific policy
  • Implement an supplier management process
  • Include in your supplier management process supplier acquisition and supplier transfer
  • Implement an ISO 27001 supplier register
  • Have agreements with all suppliers that cover information security requirements
  • Have information security assurances for critical suppliers as a minimum and ideally all relevant suppliers

How to pass the audit

To pass an audit of ISO 27001 Annex A 5.21 Managing information security in the ICT supply chain you are going to make sure that you have followed the steps above in how to comply.

What an auditor will check

The audit is going to check a number of areas. Lets go through the most common

1. That you have a supplier agreements in place

The auditor is going to check that you have agreements in place with suppliers that cover the information security requirements. It will check that those agreements are in date and cover the products and / or services acquired.

2. That you have an ISO 27001 Supplier Register

You will need an ISO 27001 Supplier Register to  record and manage your suppliers. Make sure it is up to date and reflects your reality.

3. Documentation

They are going to look at audit trails and all your documentation and see that is classified and labelled. All the documents that you show them, as a minimum if they are confidential should be labelled as such. Is the document up to date. Has it been reviewed in the last 12 months. Does the version control match.

Top 3 Mistakes People Make

The top 3 Mistakes People Make For ISO 27001 Annex A 5.21 are

Make sure that there is a contract, agreement, terms of business or some legal mechanism for engaging with suppliers and you have a copy, it is in date and covers what you are using.

2. You have no assurance they are doing the right thing for information security

Make sure you have done your security assessment and can place your hands on an in date certificate such as an ISO 27001 Certification for assurance they are doing the right thing. It needs to be in date a cover the products and / or services you have acquired and are using form the supplier.

3. Your document and version control is wrong

Keeping your document version control up to date, making sure that version numbers match where used, having a review evidenced in the last 12 months, having documents that have no comments in are all good practices.

ISO 27001 Annex A 5.21 FAQ

What policies do I need for ISO 27001 Annex A 5.21 Managing information security in the ICT supply chain?

For ISO 27001 Annex A 5.21 Managing information security in the ICT supply chain you will need the ISO 27001 Supplier Policy

Why is managing information security in the ICT supply chain Important?

ISO 27001 Annex A 5.21 Managing information security in the ICT supply chain is important because suppliers represent the biggest risk to you. If they are not doing the right thing it is your reputation, your finances, your success that is stake. Get supplier management correct and reduce the risk.

Will I require legal support for ISO 27001 Annex A 5.21

Yes. The support of a legal professional is strongly advised.

Are there templates for ISO 27001 Annex A 5.21?

There are templates that support ISO 27001 Annex A 5.21 located in the ISO 27001 Toolkit.

Do I have to satisfy ISO 27001 Annex A 5.21 for ISO 27001 Certification?

Yes. Whilst the ISO 27001 Annex A clauses are for consideration to be included in your Statement of Applicability there is no reason we can think of that would allow you to exclude ISO 27001 Annex A 5.21 Managing information security in the ICT supply chain is a fundamental part of your control framework and any management system. It is explicitly required for ISO 27001.

Can I write polices for ISO 27001 Annex A 5.21 myself?

Yes. You can write the policies forISO 27001 Annex A 5.21 yourself. You will need a copy of the standard and approximately 5 days of time to do it. It would be advantageous to have a background in information security management systems.

Where can I get templates for ISO 27001 Annex A 5.21?

ISO 27001 templates that support ISO 27001 Annex A 5.21 are located in the ISO 27001 Toolkit.

How hard is ISO 27001 Annex A 5.21?

ISO 27001 Annex A 5.21 is hard. The documentation required is extensive. We would recommend templates to fast track your implementation.

How long will ISO 27001 Annex A 5.21 take me?

ISO 27001 Annex A 5.21 will take approximately 1 to 3 month to complete if you are starting from nothing and doing a full implementation. With the right risk management approach and an ISO 27001 Toolkit it should take you less than 1 day.

How much will ISO 27001 Annex A 5.21 cost me?

The cost of ISO 27001 Annex A 5.21 will depend how you go about it. If you do it yourself it will be free but will take you about 1 to 3 months so the cost is lost opportunity cost as you tie up resource doing something that can easily be downloaded and managed via risk management.

ISO 27001 Annex A 5.30 ICT Readiness For Business Continuity

ISO 27001 Annex A 5.20 Addressing Information Security Within Supplier Agreements

Further Reading

The complete guide to ISO/IEC 27002:2022

ISO 27001 controls and attribute values

Control typeInformation
security properties
Cybersecurity
concepts
Operational
capabilities
Security domains
PreventiveConfidentialityIdentifySupplier relationships securityProtection
IntegrityGovernance and ecosystem
Availability

About the author

Stuart Barker is a veteran practitioner with over 30 years of experience in systems security and risk management.

Holding an MSc in Software and Systems Security, Stuart combines academic rigor with extensive operational experience. His background includes over a decade leading Data Governance for General Electric (GE) across Europe, as well as founding and exiting a successful cyber security consultancy.

As a qualified ISO 27001 Lead Auditor and Lead Implementer, Stuart possesses distinct insight into the specific evidence standards required by certification bodies. He has successfully guided hundreds of organizations – from high-growth technology startups to enterprise financial institutions – through the audit lifecycle.

His toolkits represents the distillation of that field experience into a standardised framework. They move beyond theoretical compliance, providing a pragmatic, auditor-verified methodology designed to satisfy ISO/IEC 27001:2022 while minimising operational friction.

ISO 27001:2022 requirements

ISO 27001 Clauses

ISO 27001 Clause 4.1 – Understanding The Organisation And Its Context

ISO 27001 Clause 4.2 – Understanding The Needs And Expectations of Interested Parties

ISO 27001 Clause 4.3 – Determining The Scope Of The Information Security Management System

ISO 27001 Clause 4.4 – Information Security Management System

ISO 27001 Clause 5.1 – Leadership and Commitment

ISO 27001 Clause 5.3 – Organisational Roles, Responsibilities and Authorities

ISO 27001 Clause 6.1.1 – Planning General

ISO 27001 Clause 6.1.2 – Information Security Risk Assessment

ISO 27001 Clause 6.1.3 – Information Security Risk Treatment

ISO 27001 Clause 6.2 – Information Security Objectives and Planning to Achieve Them

ISO 27001 Clause 6.3 – Planning Of Changes

ISO 27001 Clause 7.1 – Resources

ISO 27001 Clause 7.2 – Competence

ISO 27001 Clause 7.3 – Awareness

ISO 27001 Clause 7.4 – Communication

ISO 27001 Clause 7.5.1 – Documented Information

ISO 27001 Clause 7.5.2 – Creating and Updating Documented Information

ISO 27001 Clause 8.3 – Information Security Risk Treatment

ISO 27001 Clause 9.1 – Monitoring, Measurement, Analysis, Evaluation

ISO 27001 Clause 9.2 – Internal Audit

ISO 27001 Clause 9.3 – Management Review

ISO 27001 Clause 10.1 – Continual Improvement

ISO 27001 Clause 10.2 – Nonconformity and Corrective Action

ISO 27001 Organisation Controls

ISO 27001 Annex A 5.1: Policies for information security

ISO 27001 Annex A 5.2: Information Security Roles and Responsibilities

ISO 27001 Annex A 5.3: Segregation of duties

ISO 27001 Annex A 5.4: Management responsibilities

ISO 27001 Annex A 5.5: Contact with authorities

ISO 27001 Annex A 5.6: Contact with special interest groups

ISO 27001 Annex A 5.7: Threat intelligence

ISO 27001 Annex A 5.8: Information security in project management

ISO 27001 Annex A 5.9: Inventory of information and other associated assets

ISO 27001 Annex A 5.10: Acceptable use of information and other associated assets

ISO 27001 Annex A 5.11: Return of assets

ISO 27001 Annex A 5.12: Classification of information

ISO 27001 Annex A 5.13: Labelling of information

ISO 27001 Annex A 5.14: Information transfer

ISO 27001 Annex A 5.15: Access control

ISO 27001 Annex A 5.16: Identity management

ISO 27001 Annex A 5.17: Authentication information

ISO 27001 Annex A 5.18: Access rights

ISO 27001 Annex A 5.19: Information security in supplier relationships

ISO 27001 Annex A 5.20: Addressing information security within supplier agreements

ISO 27001 Annex A 5.21: Managing information security in the ICT supply chain

ISO 27001 Annex A 5.22: Monitoring, review and change management of supplier services

ISO 27001 Annex A 5.23: Information security for use of cloud services

ISO 27001 Annex A 5.24: Information security incident management planning and preparation

ISO 27001 Annex A 5.25: Assessment and decision on information security events

ISO 27001 Annex A 5.26: Response to information security incidents

ISO 27001 Annex A 5.27: Learning from information security incidents

ISO 27001 Annex A 5.28: Collection of evidence

ISO 27001 Annex A 5.29: Information security during disruption

ISO 27001 Annex A 5.30: ICT readiness for business continuity

ISO 27001 Annex A 5.31: Identification of legal, statutory, regulatory and contractual requirements

ISO 27001 Annex A 5.32: Intellectual property rights

ISO 27001 Annex A 5.33: Protection of records

ISO 27001 Annex A 5.34: Privacy and protection of PII

ISO 27001 Annex A 5.35: Independent review of information security

ISO 27001 Annex A 5.36: Compliance with policies and standards for information security

ISO 27001 Annex A 5.37: Documented operating procedures

ISO 27001 Technical Controls

ISO 27001 Annex A 8.1: User Endpoint Devices

ISO 27001 Annex A 8.2: Privileged Access Rights

ISO 27001 Annex A 8.3: Information Access Restriction

ISO 27001 Annex A 8.4: Access To Source Code

ISO 27001 Annex A 8.5: Secure Authentication

ISO 27001 Annex A 8.6: Capacity Management

ISO 27001 Annex A 8.7: Protection Against Malware

ISO 27001 Annex A 8.8: Management of Technical Vulnerabilities

ISO 27001 Annex A 8.9: Configuration Management 

ISO 27001 Annex A 8.10: Information Deletion

ISO 27001 Annex A 8.11: Data Masking

ISO 27001 Annex A 8.12: Data Leakage Prevention

ISO 27001 Annex A 8.13: Information Backup

ISO 27001 Annex A 8.14: Redundancy of Information Processing Facilities

ISO 27001 Annex A 8.15: Logging

ISO 27001 Annex A 8.16: Monitoring Activities

ISO 27001 Annex A 8.17: Clock Synchronisation

ISO 27001 Annex A 8.18: Use of Privileged Utility Programs

ISO 27001 Annex A 8.19: Installation of Software on Operational Systems

ISO 27001 Annex A 8.20: Network Security

ISO 27001 Annex A 8.21: Security of Network Services

ISO 27001 Annex A 8.22: Segregation of Networks

ISO 27001 Annex A 8.23: Web Filtering

ISO 27001 Annex A 8.24: Use of Cryptography

ISO 27001 Annex A 8.25: Secure Development Life Cycle

ISO 27001 Annex A 8.26: Application Security Requirements

ISO 27001 Annex A 8.27: Secure Systems Architecture and Engineering Principles

ISO 27001 Annex A 8.28: Secure Coding

ISO 27001 Annex A 8.29: Security Testing in Development and Acceptance

ISO 27001 Annex A 8.30: Outsourced Development

ISO 27001 Annex A 8.31: Separation of Development, Test and Production Environments

ISO 27001 Annex A 8.32: Change Management

ISO 27001 Annex A 8.33: Test Information

ISO 27001 Annex A 8.34: Protection of information systems during audit testing