Outsourcing your software development is a fantastic way to access talent and speed up delivery, but it can also be a security nightmare. When you hand over the keys to your code to a third party, you aren’t just outsourcing the work—you are outsourcing a significant amount of risk.
ISO 27001:2022 Annex A 8.30, “Outsourced development,” is designed to bring that risk back under control. It ensures that just because the code is being written outside your building, it doesn’t mean it is being written outside your security standards.
Table of contents
What is the Objective of Annex A 8.30?
The core objective is to ensure that any outsourced systems development is supervised and monitored. You need to verify that the external party is applying the same level of security rigour that you would expect from your own internal team. This covers the entire lifecycle—from the moment you sign the contract to the final line of code being delivered.
If a vendor delivers code full of backdoors or vulnerabilities, the blame (and the data breach) will ultimately land on your desk, not theirs. Annex A 8.30 helps you prevent that scenario.
Step-by-Step Implementation Guide
Implementing this control requires a shift from a “trust” mindset to a “verify” mindset. Here is how to structure your approach effectively.
1. Due Diligence and Vendor Selection
Before a single line of code is written, you must vet your developer. Don’t just look at their portfolio or their price; look at their security posture. Do they have their own ISO 27001 certification? do they follow secure coding practices like OWASP? According to the guidance from Hightable.io, conducting thorough due diligence is the first line of defence. If they cannot prove they take security seriously during the sales pitch, they certainly won’t do it during the project.
2. The Contract is King
This is the most critical step. Your expectations must be legally binding. A vague promise to “write secure code” is not enough. Your agreement should specify:
- Secure Coding Standards: Explicitly state which standards (e.g., OWASP Top 10) must be followed.
- Testing Requirements: Require evidence of Static Application Security Testing (SAST) and Dynamic Application Security Testing (DAST) before delivery.
- Right to Audit: You must reserve the right to audit their development processes and code repositories.
- Intellectual Property (IP): Clearly define who owns the code and who is responsible if the code infringes on third-party IP or contains unauthorised open-source libraries.
3. Secure Design and Architecture
You cannot simply throw a feature request over the wall and wait for the result. You need to share your secure architecture principles with the vendor. If your internal policy requires all data to be encrypted at rest, the outsourced developer needs to know this before they design the database schema. Share your threat models with them so they understand the risks specific to your business environment.
4. Monitoring and Supervision
Outsourcing is not “fire and forget.” You need to monitor the development activity. This doesn’t mean micromanaging every sprint, but it does mean having regular security checkpoints. Hightable.io suggests that you should direct, monitor, and review the activities regularly. This could involve reviewing their vulnerability scan reports or having a member of your security team sit in on their sprint reviews.
5. Acceptance Testing
Never accept code blindly. Before the code is merged into your production environment, it must pass your acceptance tests. This goes beyond checking if the features work; it includes checking for security flaws. Scan the delivered code for malware, hard-coded credentials, and known vulnerabilities. If the code doesn’t meet your security threshold, reject it just as you would if it didn’t function correctly.
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Key Challenges to Watch For
The “Black Box” Problem: Vendors often try to hide their internal processes. Push for transparency. You need to know if they are outsourcing the work again to a fourth party (sub-contracting), which introduces even more risk.
Licensing Issues: Developers often copy-paste code from libraries. Ensure you have a process to check for “poison pill” open-source licences that could force you to make your proprietary code public.
A Quick Checklist for Annex A 8.30
To ensure you are ready for your audit, verify the following:
- Is security explicitly mentioned in the contract or Statement of Work (SOW)?
- Have you defined the secure coding standards the vendor must follow?
- Do you have evidence of security testing (scans, pentests) performed on the delivered code?
- Have you checked for malware and unauthorised code snippets before acceptance?
- Is there a “Right to Audit” clause in your agreement?
- Have you clarified IP ownership and open-source licensing usage?
Conclusion
Implementing Annex A 8.30 is about extending your security perimeter to include your partners. By setting clear contractual boundaries, defining your security requirements upfront, and rigorously testing what is delivered, you can enjoy the benefits of outsourced development without inheriting its worst risks.
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.
