ISO 27001:2022 Annex A 5.22 Monitoring, review and change management of supplier services

In this guide, I will show you exactly how to implement ISO 27001 Annex A 5.22 and ensure you pass your audit. You will get a complete walkthrough of the control, practical implementation examples, and access to the ISO 27001 templates and toolkit that make compliance easy.

I am Stuart Barker, an ISO 27001 Lead Auditor with over 30 years of experience conducting hundreds of audits. I will cut through the jargon to show you exactly what changed in the 2022 update and provide you with plain-English advice to get you certified.

Key Takeaways: ISO 27001 Annex A 5.22 Monitoring, Review, and Change Management of Supplier Services

ISO 27001 Annex A 5.22 requires organizations to regularly monitor, review, and evaluate supplier service delivery. This control ensures that the information security practices agreed upon in your contracts (Annex A 5.20) are actually being followed in reality. In a modern “SaaS-first” business, suppliers are your biggest risk; this “preventive” control ensures that you maintain oversight of their performance, respond to their security incidents, and manage any changes they make to their services without compromising your own security posture.

Core requirements for compliance include:

• Continuous Performance Monitoring: You must track supplier performance against agreed service levels (SLAs). This is typically done through monthly or quarterly service reports and dashboards.
• Regular Security Reviews: Critical suppliers should be evaluated at least annually. This involves verifying they still hold valid certifications (like ISO 27001 or SOC 2) and haven’t experienced major security regressions.
• Supplier Change Management: You must monitor and respond to changes made by the supplier, such as updates to their software, changes in their sub-processors, or shifts in their data hosting locations.
• Incident & Problem Management: Organizations must have a structured way to respond when a supplier has a security breach or a service outage, ensuring that the impact on your business is minimized.
• Audit Rights Execution: If your contract includes a “Right to Audit,” you should periodically exercise it, either through a direct audit or by reviewing the supplier’s third-party assurance reports.
• Centralized Supplier Register: All monitoring activities and review outcomes should be recorded in an up-to-date Supplier Register.

Audit Focus: Auditors will look for “The Oversight Trail”:

1. Evidence of Review: “Show me the minutes from your last quarterly review meeting with your critical hosting provider. What security issues were discussed?”
2. Assurance Verification: “Show me the current ISO 27001 certificate for your payroll provider. When does it expire, and who is responsible for checking it?”
3. Change Impact: “When your CRM provider moved their data storage from the US to the EU, how did you assess the impact on your data privacy compliance?”

Monitoring Metrics Matrix (Audit Prep):

Metric Type	Critical Focus	Review Frequency	Target “Good” Score
Availability	System Uptime (SLA).	Monthly.	> 99.9%
Responsiveness	Incident Ticket Reply Time.	Quarterly.	< 4 Hours.
Assurance	Valid ISO 27001 / SOC 2 Cert.	Annually.	Valid & In-Scope.
Security	Number of Data Breaches.	Ad-hoc / Continuous.	0 Reported.

What is ISO 27001 Annex A 5.22?

ISO 27001 Annex A 5.22 is ensuring the confidentiality, integrity and availability of your suppliers, their products and their services through monitoring and review.

ISO 27001 Annex A 5.22 Monitor, review and change management of supplier services is an ISO 27001 control that requires an organisation to maintain an agreed level of service and information security in line with legal agreements.

ISO 27001 Annex A 5.22 Purpose

The purpose of ISO 27001 Annex A 5.22 is a preventive control that ensures you maintain an agreed level of information security and service delivery in line with supplier agreements.

ISO 27001 Annex A 5.22 Definition

The ISO 27001 standard defines ISO 27001 Annex A 5.22 as:

The organisation should regularly monitor, review, evaluate and manage change in supplier information security practices and service delivery.

ISO 27001:2022 Annex A 5.22 Monitor, review and change management of supplier services

Watch the ISO 27001 Annex A 5.22 Tutorial

In the video ISO 27001 Monitoring Review Change Management of Supplier Services Explained – ISO27001 Annex A 5.22 I show you how to implement it and how to pass the audit.

ISO 27001 Annex A 5.22 Podcast

In this episode: Lead Auditor Stuart Barker and team do a deep dive into the ISO 27001 Annex A 5.22 Monitor, Review And Change Management Of Supplier Services. The podcast explores what it is, why it is important and the path to compliance.

How to implement ISO 27001 Annex A 5.22

As with all the clauses that relate to supplier management we are looking to assign the responsibility to a person or a team with the skills and resources to be able to track that requirements are being met and where not, they are being addressed.

In basic terms it is about making sure that the terms and conditions in legal agreements that relate to information security are being met. It is about managing issues, problems and incidents as the occur and if changes are needed to suppliers that those changes do not adversely impact the business.

You are going to:

• Those service performance levels are going to be monitored, most likely via reports or metrics or dashboards.
• Check and respond to changes made by suppliers such as updates, changes to process, changes to controls
• Where supplier services change to monitor and respond to those
• Keep your eye on the terms and conditions of the agreements and that they are followed
• Ensure those pesky suppliers are evaluated and maintain adequate security

It isn’t really that hard although you can over complicate it very easily. Have agreements in place, make sure they are followed, check them and respond when things go wrong.

We are not teaching people how to do supplier management or change it. What is here is common sense.

Monitoring Metrics Matrix

Metric	Description	Frequency	Good Score
Uptime (SLA)	Is the service available?	Monthly	> 99.9%
Incident Response	How fast do they reply to tickets?	Quarterly	< 4 Hours
Security Audits	Do they have a valid ISO 27001 cert?	Annually	Valid / Pass
Data Breaches	Have they reported any leaks?	Ad-hoc	0

ISO 27001 Supplier Register Template

The ultimate ISO 27001 Supplier Register Template.

ISO 27001 Supplier Policy Template

The ultimate ISO 27001 Supplier Register Template.

How to comply

To comply with ISO 27001 Annex A 5.22 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 a 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
• Monitor those suppliers
• Respond to adverse incidents in a structured way

How to pass an ISO 27001 Annex A 5.22 audit

To pass an audit of ISO 27001 Annex A 5.22 Monitor, review and change management of supplier services you are going to make sure that you have followed the steps above in how to comply.

What the 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 ISO 27001 Annex A 5.22 Mistakes People Make and How to Avoid Them

The top 3 Mistakes People Make For ISO 27001 Annex A 5.22 are

1. You have do not monitor suppliers

Make sure that there are reviews and monitors in place. Perhaps meetings. Perhaps reports. Perhaps dashboards. Be sure to be able to evidence that you review and monitor those suppliers. You will have processes for adverse advents so do not be surprised if you are asked to evidence an adverse event, problem or issue and that you followed your process.

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.

Fast Track ISO 27001 Annex A 5.22 Compliance with the ISO 27001 Toolkit

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For ISO 27001 Annex A 5.22 (Monitoring, review and change management of supplier services), the requirement is to regularly monitor, review, and evaluate supplier information security practices and service delivery. This ensures that the security levels agreed upon in contracts are actually being maintained throughout the life of the relationship.

While SaaS compliance platforms often try to sell you “automated vendor monitoring” or complex “SLA dashboards,” they cannot actually attend a quarterly business review (QBR) for you or evaluate how a vendor’s change in ownership might affect your risk profile, those are human governance and relationship management tasks. The High Table ISO 27001 Toolkit is the logical choice because it provides the monitoring framework you need to manage supplier performance effectively without a recurring subscription fee.

1. Ownership: You Own Your Supplier Monitoring Logs Forever

SaaS platforms act as a middleman for your compliance evidence. If you define your monitoring metrics and store your review records inside their proprietary system, you are essentially renting your own supplier history.

• The Toolkit Advantage: You receive the Supplier Policy and Supplier Register (which includes monitoring fields) in fully editable Word/Excel formats. These files are yours forever. You maintain permanent ownership of your records (such as your history of vendor SLA performance), ensuring you are always ready for an audit without an ongoing “rental” fee.

2. Simplicity: Governance for Real-World Vendor Management

Annex A 5.22 is about checking that vendors do what they promised. You don’t need a complex new software interface to record that a vendor’s ISO 27001 certificate is still in date or that they met their 99.9% uptime target.

• The Toolkit Advantage: Your team already receives status reports and uptime alerts. What they need is the governance layer to prove to an auditor that these reports are reviewed and that any changes (like a new API version) are risk-assessed. The Toolkit provides pre-written procedures and “Monitoring Metrics Matrices” that formalize your existing relationship management into an auditor-ready framework, without forcing your team to learn a new software platform just to log a meeting.

3. Cost: A One-Off Fee vs. The “Vendor Volume” Tax

Many compliance SaaS platforms charge based on the number of “monitored vendors” or “third-party reviews” you conduct. For a control that requires you to keep an eye on every critical supplier, these monthly costs can scale aggressively.

• The Toolkit Advantage: You pay a single, one-off fee for the entire toolkit. Whether you monitor 5 critical vendors or 50, the cost of your Supplier Monitoring Documentation remains the same. You save your budget for actual security improvements or better-tier vendor support rather than an expensive compliance dashboard.

4. Freedom: No Vendor Lock-In for Your Review Strategy

SaaS tools often mandate specific review cycles or rigid scoring for vendor performance. If their system doesn’t match your unique business requirements or specialized industry SLAs, the tool becomes a bottleneck to efficiency.

• The Toolkit Advantage: The High Table Toolkit is 100% technology-agnostic. You can tailor the Monitoring Procedures to match exactly how you operate, whether you conduct deep-dive annual audits or simple quarterly metric checks. You maintain total freedom to evolve your vendor review strategy without being constrained by the technical limitations of a rented SaaS platform.

Summary: For Annex A 5.22, the auditor wants to see that you are actively monitoring your suppliers and have a process for managing changes to their services. The High Table ISO 27001 Toolkit provides the governance framework to satisfy this requirement immediately. It is the most direct, cost-effective way to achieve compliance using permanent documentation that you own and control.

ISO 27001 Annex A 5.22 FAQ

Related ISO 27001 Controls

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

Further Reading

ISO 27001 Supplier Security Policy Beginner’s Guide

ISO 27001 controls and attribute values

Control type	Information security properties	Cybersecurity concepts	Operational capabilities	Security domains
Preventive	Confidentiality	Identify	Supplier relationships security	Protection
	Integrity			Governance and ecosystem
	Availability			Defence
				Information security assurance

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.