ISO 27001 Annex A 5.4 Audit Checklist

Auditing ISO 27001 Annex A 5.4 Management Responsibilities involves the rigorous verification of leadership’s active role in information security governance. This process validates the Primary Implementation Requirement that management defines, mandates, and resources the ISMS. The Business Benefit ensures security initiatives are strategically aligned with business goals and culturally enforced from the top down.

This professional audit verification tool is designed to evaluate the effectiveness of leadership engagement and accountability within the ISMS. Use this checklist to validate compliance with ISO 27001 Annex A 5.4 (Management Responsibilities) by verifying that leadership actively enforces information security across the organisation.

1. Management Enforcement of Security Policies Verified

Verification Criteria: Evidence exists that management explicitly requires all personnel and relevant interested parties to apply information security in accordance with established policies.

Required Evidence: Clauses in employment contracts, signed employee handbooks, or contractor agreements that mandate adherence to the Information Security Policy.

Pass/Fail Test: If there is no documented mandate from management requiring staff to follow security policies within their contractual obligations, mark as Non-Compliant.

2. Tone at the Top and Security Culture Validation Confirmed

Verification Criteria: Management demonstrates a clear “tone at the top” by actively promoting security awareness and compliance through internal communications.

Required Evidence: Emails, newsletters, or video briefings from executive leadership (C-suite) specifically addressing the importance of information security during the current audit period.

Pass/Fail Test: If security communications only originate from the IT/Security department without visible endorsement from senior business leadership, mark as Non-Compliant.

3. Provisioning of Information Security Resources Evidenced

Verification Criteria: Management ensures that the resources required for the ISMS (personnel, budget, and technology) are identified, allocated, and adequate for the risk landscape.

Required Evidence: Approved ISMS budget, resource allocation plans, or organograms showing dedicated security roles with sufficient headcount.

Pass/Fail Test: If critical security projects are stalled or roles remain vacant for over 6 months due to a lack of management-authorised funding/resources, mark as Non-Compliant.

4. Formal Disciplinary Process for Security Breaches Verified

Verification Criteria: A formal disciplinary process exists and is communicated for personnel who have committed an information security breach.

Required Evidence: Human Resources Disciplinary Policy containing specific sections or clauses related to information security violations.

Pass/Fail Test: If the disciplinary policy does not explicitly mention security non-compliance as a ground for corrective action, mark as Non-Compliant.

5. Security KPI Integration in Performance Reviews Confirmed

Verification Criteria: Information security responsibilities are integrated into the standard performance management and appraisal processes for all staff.

Required Evidence: Sampled performance appraisal templates or completed review records showing security-related objectives or KPIs.

Pass/Fail Test: If staff performance is evaluated solely on business output with no regard for security policy adherence or training completion, mark as Non-Compliant.

6. Strategic Alignment of Security Objectives Validated

Verification Criteria: Management ensures that information security objectives are established and are compatible with the strategic direction of the organisation.

Required Evidence: Strategic business plans or Board meeting minutes where security objectives are mapped against business goals.

Pass/Fail Test: If security objectives are developed in isolation by the IT department and are unknown to executive management, mark as Non-Compliant.

7. Management Participation in ISMS Reviews Evidenced

Verification Criteria: Senior management actively participates in the Management Review of the ISMS to evaluate its continuing suitability and effectiveness.

Required Evidence: Management Review Meeting (MRM) minutes showing attendance by Top Management and their sign-off on review outputs.

Pass/Fail Test: If the Management Review is conducted by the CISO alone without the participation or final approval of executive leadership, mark as Non-Compliant.

8. Reporting Lines for Security Leadership Verified

Verification Criteria: The individual responsible for information security has a clear reporting line to senior management to ensure independence and authority.

Required Evidence: Current organisational chart and job description for the CISO/Security Lead showing a direct or dotted line to the CEO or Board.

Pass/Fail Test: If the security function is buried under several layers of IT management with no access to executive leadership, mark as Non-Compliant.

9. Internal Promotion of Security Continuous Improvement Confirmed

Verification Criteria: Management actively supports and directs the continual improvement of the ISMS based on audit findings and risk assessments.

Required Evidence: Corrective Action Plans (CAPs) approved by management following internal or external audits.

Pass/Fail Test: If audit non-conformities are ignored by management or lack an authorised budget for remediation, mark as Non-Compliant.

10. Communication of Organisational Role Changes Verified

Verification Criteria: Management ensures that changes to security-related roles and responsibilities are communicated effectively to the relevant staff.

Required Evidence: Internal announcements, updated RACI matrices, or role-change notification logs sent to affected personnel.

Pass/Fail Test: If key security accountabilities change but personnel are found to be unaware of their updated duties, mark as Non-Compliant.

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