In this guide, I will show you exactly how to implement ISO 27001 Annex A 5.4 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 5.4 Management Responsibilities
ISO 27001 Annex A 5.4 requires senior management to actively ensure that all personnel follow the organization’s information security policies and procedures. This control shifts security from being “the IT department’s problem” to a top-down leadership mandate. The goal is to ensure that management understands their role in fostering a security culture and provides the necessary resources, oversight, and legal frameworks to enforce data protection standards across the entire workforce.
- Leaders are responsible for making sure everyone follows the security rules.
- Companies need to train their staff so they know their part in keeping information safe.
- Clear security policies and job duties should be written down for all to see.
Core requirements for compliance include:
- Mandated Compliance: Management must require all staff and contractors to apply information security in accordance with established policies. This isn’t optional; it must be a condition of employment.
- Resource Allocation: Leaders must provide adequate resources (budget, time, and tools) to implement and maintain the Information Security Management System (ISMS).
- Competence & Skills: Management is responsible for ensuring that personnel are competent for their security roles. This involves maintaining a Competency Matrix to track training, experience, and certifications.
- Contractual Enforcement: Security requirements must be explicitly stated in employment contracts and third-party agreements to ensure they are legally enforceable.
- Whistleblowing Process: Management must implement a process that allows employees to report security concerns or violations anonymously and without fear of retaliation.
Audit Focus: Auditors will look for “The Leadership Signature”:
- Direct Evidence: “Show me the meeting minutes where senior management reviewed the risk register and approved the security budget.”
- The Whistleblower Test: “If an employee sees a manager bypassing security rules, how do they report it? Show me the documented process.”
- Policy Acknowledgement: They will check if all new hires, including senior executives, have signed their employment contracts and completed their initial security training.
Manager’s Monthly Checklist (Audit Prep):
| Action | Why it matters | Required Evidence | ISO 27001:2022 Control |
|---|---|---|---|
| Brief the Team | Reminds staff of specific security behaviors (e.g., screen locking). | Team meeting minutes. | Annex A 5.4 / 7.3 |
| Check Compliance | Verifies that all team members completed annual security training. | Updated Training Log. | Annex A 5.4 / 7.2 |
| Enforce Rules | Demonstrates that policy violations have consequences. | Disciplinary note or email record. | Annex A 5.4 / 5.4 |
| Lead by Example | Sets the cultural tone for the organization. | Visual observation (e.g., wearing ID badges). | Annex A 5.4 / Clause 5.1 |
Table of Contents
- What is ISO 27001 Annex A 5.4?
- Watch the ISO 27001 Annex A 5.4 Tutorial
- ISO 27001 Annex A 5.4 Podcast
- ISO 27001 Annex A 5.4 Implementation Guidance
- How to implement ISO 27001 Annex A 5.4
- ISO 27001 Roles and Responsibilities Template
- ISO 27001 Competency Template
- Manager’s Monthly Checklist Example
- How to comply
- How to pass the ISO 27001 Annex A 5.4 audit
- How to audit ISO 27001 Annex A 5.4 audit
- Top 3 ISO 27001 Annex A 5.4 Mistakes and How to Fix Them
- Applicability of ISO 27001 Annex A 5.4 across different business models.
- Fast Track ISO 27001 Annex A 5.4 Compliance with the ISO 27001 Toolkit
- ISO 27001 Annex A 5.4 FAQ
- Related ISO 27001 Controls
- Further Reading
- ISO 27001 Controls and Attribute Values
What is ISO 27001 Annex A 5.4?
ISO 27001 Management Responsibilities is ensuring that information security is led from the top down.
ISO 27001 Annex A 5.4 Management Responsibilities is an ISO 27001 control that requires management to ensure that people apply information security in line with documented policies and procedures.
ISO 27001 Annex A 5.4 Purpose
The purpose of Annex A 5.4 is to ensure management understand their role in information security and undertake actions aiming to ensure all personnel are aware of and fulfil their information security responsibilities.
ISO 27001 Annex A 5.4 Definition
The ISO 27001 standard defines ISO 27001 Management Responsibilities as:
Management should require all personnel to apply information security in accordance with the established information security policy, topic-specific policies and procedures of the organization.
ISO 27001 Annex A 5.4 Management Responsibilities
Watch the ISO 27001 Annex A 5.4 Tutorial
In the video ISO 27001 Annex A 5.4 Management Responsibilities Explained I show you how to implement it and how to pass the audit.
ISO 27001 Annex A 5.4 Podcast
In this episode: Lead Auditor Stuart Barker and team do a deep dive into the ISO 27001 Annex A 5.4 Management Responsibilities. The podcast explores what it is, why it is important and the path to compliance.
ISO 27001 Annex A 5.4 Implementation Guidance
You are going to have to ensure that:
- information security roles and responsibilities are documented and people are briefed on them before they get access to information
- guidelines for information security expectations are in place and they are shared with people
- information security policies are in place and people are aware that they are mandated
- implement information security training and awareness relevant to people’s roles
- have terms and conditions of employment, contracts or agreements that include information security and relate to the policies
- information security skills and qualifications where relevant are ongoing
- you have a whistleblowing process
- adequate resources are made available for information security related controls and processes.
1. Implement ISO 27001 Policies
To act in accordance with ISO 27001 information security policies and procedures you first need to implement them. Follow the guidance in The Ultimate Guide to ISO 27001 Annex A 5.1 Policies for Information Security
2. Document Roles and Responsibilities
It is straight forward to document the roles and responsibilities. Start with defining what the roles are. You state the name of the role and then list what the role is responsible for in terms of information security.
Example Information Security Roles
Typical roles that are required include, but is certainly not limited to:
- CEO
- Leadership
- Information Security Management Leadership
- Information Security Manager
- Management Review Team
- Third Party Supplier Manager
- Business Continuity Manager
- Information Owners
- Information Security Incident Management
Example Information Security Responsibilities
An example of information security responsibilities assigned to a role would be the role of the CEO. Let’s take a look:
CEO
- Sets the company direction for information security
- Promotes a culture of information security aligned to the business objectives
- Signs off and agrees on resources, objectives, risks and risk treatment
3. Ensure People are Competent
Once people are assigned then we are going to record and manage their competence to perform the role. Usually this is a measure of experience and training. You are going to create and maintain an ISO 27001 Competency Matrix.
4. Engage with HR
You have a reliance on HR. There are many HR process that will come into play throughout the implementation, including on boarding new employees, off boarding when people leave, disciplinary processes and more. Specific to this particular clause you are going to have terms and conditions of employment, contracts or agreements that include information security and relate to the policies. You are going to work to ensure that information security is part of all HR process as appropriate.
5. Communicate and Train
A large part of this control is communication and training. Actually telling people what is expected of them. Having a communication plan in place that covers what you will communicate, when, to whom and how is a great way to set a structure for the year. Telling people where policies are, how to report incidents, who they can speak to about information security are some of the basics. Alongside this you will have training on a range of topics and requirements – you can learn more in The Ultimate Guide to ISO 27001 Annex A 6.3 Information Security Awareness, Education and Training
For further guidance read How to Implement ISO 27001:2022 Annex A 5.4
How to implement ISO 27001 Annex A 5.4
Implementing ISO 27001 Annex A 5.4 requires a shift from passive approval to active security leadership. This control mandates that management at all levels demonstrates a commitment to the Information Security Management System (ISMS) by ensuring personnel follow established security protocols. By embedding security requirements into daily operations and human resource processes, organisations create a culture of accountability. This technical guide outlines the action-oriented steps to formalise management oversight and satisfy lead auditor requirements for the 2022 standard.
1. Formalise Information Security Roles and Responsibilities
Establish clear lines of accountability by documenting security duties within job descriptions and organisational charts. This action results in a structured governance framework where every employee and manager understands their specific obligations toward data protection.
- Define specific security roles using a RACI matrix (Responsible, Accountable, Consulted, Informed) to eliminate ambiguity in decision making.
- Incorporate security-related performance objectives into annual staff appraisals to incentivise policy adherence.
- Assign Identity and Access Management (IAM) oversight roles to departmental managers to ensure the principle of least privilege is maintained for their teams.
2. Provision Resources for Technical and Organisational Controls
Execute the allocation of budget, personnel, and technology required to maintain the ISMS. This result-focused step ensures that security initiatives are not delayed by resource constraints and that the organisation possesses the tools necessary to defend its information assets.
- Allocate dedicated funding for critical technical safeguards, such as Multi-Factor Authentication (MFA) and Endpoint Detection and Response (EDR) solutions.
- Provision time for staff to engage in mandatory security awareness training and incident response tabletop exercises.
- Ensure the availability of Subject Matter Experts (SMEs) to guide project teams on security-by-design principles.
3. Enforce Policy Adherence Through Visible Leadership
Demonstrate management commitment by lead-by-example participation in security protocols. This action results in increased workforce engagement and validates the importance of the Acceptable Use Policy (AUP) across the entire hierarchy.
- Require senior leadership to sign off on core security policies, documenting their approval for audit evidence.
- Ensure managers regularly communicate security updates and threat alerts during departmental briefings.
- Verify that leadership personnel undergo the same rigorous background screening and training requirements as junior staff to maintain internal trust.
4. Establish a Formalised Disciplinary Process for Security Violations
Coordinate with Human Resources to document a transparent process for handling security non-compliance. This action results in a credible deterrent against negligence and provides a clear “Rules of Engagement” (ROE) document for policy enforcement.
- Define a tiered disciplinary framework that distinguishes between accidental errors and intentional policy violations.
- Ensure the disciplinary process is communicated clearly to all employees during the onboarding phase.
- Maintain confidential logs of disciplinary actions taken as evidence for auditors to prove the control is active and enforced.
5. Execute Regular Management Reviews of Security Performance
Perform structured reviews of ISMS metrics, audit findings, and incident reports. This result-oriented step allows management to identify systemic weaknesses and authorise corrective actions to ensure continuous improvement.
- Schedule quarterly management review meetings in alignment with ISO 27001 Clause 9.3 requirements.
- Analyse Key Performance Indicators (KPIs), such as the time taken to revoke access for leavers or training completion rates.
- Document the minutes and action items from these reviews to provide a verifiable trail of management involvement in security governance.
ISO 27001 Roles and Responsibilities Template
The Documented Roles and Responsibilities Template has the roles already defined with the responsibilities already written.
ISO 27001 Competency Template
For competency the great ISO 27001 Competency Matrix will get you up to speed fast.
Manager’s Monthly Checklist Example
| Action | Why? | Evidence |
| Brief Team | Remind staff of policies (e.g., locking screens). | Meeting Minutes. |
| Check Compliance | Verify staff completed security training. | Training Log. |
| Enforce Rules | Correct bad behavior (e.g., password sharing). | Disciplinary Note / Email. |
| Lead by Example | Wear ID badge visible at all times. | Visual Observation (Audit). |
How to comply
To comply with ISO 27001 Annex A 5.4 you are going to implement the ‘how’ to the ‘what’ the control is expecting. In short measure you are going to:
- Document your information security roles and responsibilities
- Implement a program of Information Security Training and Awareness and maintain a Communication Plan
- Implement Information Security Management Policies
- Engage a HR specialist to ensure your HR documentation is legal and meets HR best practice
- Ensure you have contracts in place with all staff, contractors and third parties
- Maintain a competency matrix to track the skills and qualifications of staff
- Implement a whistleblowing process
- Free people’s time to work on information security or bring in specialist help
How to pass the ISO 27001 Annex A 5.4 audit
To pass an audit of ISO 27001 Annex A 5.4 Management Responsibilities you are going to make sure that you have followed the steps above in how to comply.
What an auditor looks for
The audit is going to check a number of areas. Lets go through the main ones
1. That you have contracts in place
What this means is that you need to show that you have in date contracts in place with all staff, contractors and third parties. Those contracts will explicitly state the informations security requirements.
2. That you have security training and awareness
You need to implement information security and awareness training relevant to people’s roles. The audit will check that the training has taken place. The audit is also going to check that people have read and accepted the policies that are also relevant to their role. This is one occasion where an information security training tool can greatly help you.
3. That you have a whistle blowing process
Often overlooked, the requirement for people to be able to report information security related issues whilst being protected. Where this is applicable the process should be documented.
How to audit ISO 27001 Annex A 5.4 audit
Read the following for guidance on How to Audit ISO 27001 Annex A 5.4
Top 3 ISO 27001 Annex A 5.4 Mistakes and How to Fix Them
In my experience, the top 3 mistakes people make for ISO 27001 Annex A 5.4 Management Responsibilities are:
1. You have no contracts in place
You need to have contracts in place and they need to include relevant information security requirements. This can often be overlooked or the contracts that you have can be out of date. It is a good idea to check before the audit.
2. One or more members of your team haven’t done what they should have done
Prior to the audit check that all members of the team have done what they should have. Do they know where the policies are? Have they acknowledged them? Did someone join last month and forget to do it? Check!
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.
Applicability of ISO 27001 Annex A 5.4 across different business models.
| Business Type | Applicability & Interpretation | Examples of Control |
|---|---|---|
| Small Businesses |
Tone from the Top. In a small team, if the owner bypasses security (e.g., sharing passwords), everyone else will too. Compliance requires management to lead by example, not just sign a policy. |
• The “CEO Training” Rule: Ensuring the Managing Director completes the same cybersecurity awareness training as the newest intern. |
| Tech Startups |
Culture over Compliance. Management responsibility isn’t just about the CISO; it’s about Engineering Leads enforcing secure coding standards. It prevents “Security” from becoming a blocker to “Shipping.” |
• Blocker Authority: Empowering Engineering Managers to block a release if security checks fail, proving that safety outranks speed. |
| AI Companies |
Ethical Oversight. Management must take responsibility for the safety of the models they release. This goes beyond data security into AI alignment and preventing misuse. |
• Model Sign-off: A “Go/No-Go” release meeting where the Head of Research must sign off on the safety report before a model is deployed. |
Fast Track ISO 27001 Annex A 5.4 Compliance with the ISO 27001 Toolkit
For ISO 27001 Annex A 5.4 (Management responsibilities), the requirement is for management to ensure that all personnel apply information security in accordance with established policies and procedures. This is about “top-down” leadership and ensuring the management team actively oversees the security culture.
| Compliance Factor | SaaS Compliance Platforms | High Table ISO 27001 Toolkit | Audit Evidence Example |
|---|---|---|---|
| Policy Ownership | Rents access to your leadership mandates; if you cancel the subscription, your documented management roles and approval history vanish. | Permanent Assets: Fully editable Word/Excel Management Responsibility Policies and Role Descriptions you own forever. | A localized “Management Responsibility Policy” signed by the CEO, defining security accountability for all department heads. |
| Leadership Utility | Attempts to “automate” leadership via dashboards that cannot conduct management reviews or decide on resource allocation. | Governance-First: Provides the framework for actual leadership engagement, policy approval, and security culture driving. | A completed “Management Review Minute” proving that leadership reviewed ISMS performance and approved the annual budget. |
| Cost Efficiency | Charges a “Leadership Tax” based on the number of admin seats or managers, creating perpetual overhead for core accountability. | One-Off Fee: A single payment covers your management governance whether you have 2 directors or 20. | Allocating budget to actual security awareness initiatives or infrastructure rather than monthly “governance dashboard” fees. |
| Strategic Freedom | Mandates rigid reporting formats that often fail to align with agile leadership styles or specialized organizational structures. | 100% Agnostic: Procedures adapt to your operating style—from flat startup structures to complex global hierarchies. | The ability to evolve your management reporting lines and security committee structure without reconfiguring a rigid SaaS module. |
Own Your ISMS, Don’t Rent It
Do it Yourself ISO 27001 with the Ultimate ISO 27001 Toolkit
Summary: For Annex A 5.4, the auditor wants to see that management is actively involved and that people are held accountable for security responsibilities. 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 5.4 FAQ
What is ISO 27001 Annex A 5.4?
ISO 27001 Annex A 5.4 is an organisational control that requires management to ensure all personnel apply information security in accordance with established policies and procedures.
- Mandates that management leads by example in information security.
- Requires that security roles and responsibilities are clearly defined.
- Ensures that staff are aware of the consequences of non-compliance.
- Links organisational policy to individual employee accountability.
Is a formal disciplinary process mandatory for Annex A 5.4?
Yes, management must establish, communicate, and maintain a formalised disciplinary process to handle employees who violate security policies.
- The process must be fair, transparent, and documented.
- It must apply to all levels of the organisation, including senior leadership.
- It serves as a deterrent against intentional or negligent security breaches.
- Evidence of the process is a primary requirement for Stage 2 audits.
What is the difference between Clause 5 and Annex A 5.4?
While Clause 5 focuses on high-level leadership and the overall ISMS strategy, Annex A 5.4 is an operational control focused on management’s role in enforcing policy adherence among staff.
- Clause 5: Strategic commitment and resource allocation from the Board.
- Annex A 5.4: Tactical enforcement and day-to-day management of people.
- Clause 5 is part of the core standard; Annex A 5.4 is a specific security control.
Who is responsible for Annex A 5.4 compliance?
Responsibility for Annex A 5.4 lies with anyone in a supervisory or leadership role, including the Board of Directors, C-suite, and departmental line managers.
- Line Managers: Ensure their direct reports follow specific security protocols.
- HR: Manages the communication of policies and the disciplinary framework.
- CISO/ISMS Manager: Provides the policies that management must enforce.
- Executive Leadership: Allocates the necessary resources for training and awareness.
What evidence do auditors look for regarding management responsibilities?
Auditors seek verifiable proof that management is actively enforcing security requirements and that employees understand their obligations.
- Signed policy acknowledgement forms (digital or physical).
- Records of security awareness training completion.
- Evidence of management review meetings regarding security performance.
- Redacted records of disciplinary actions taken following security incidents.
How can management demonstrate commitment to ISO 27001?
Management demonstrates commitment by integrating security into business processes and ensuring that security objectives are aligned with organisational goals.
- Providing adequate budget and personnel for security initiatives.
- Promoting a “security-first” culture through regular internal communications.
- Participating in the incident response and business continuity planning process.
- Ensuring that information security is a standing agenda item in board meetings.
Related ISO 27001 Controls
ISO 27001 Annex A 5.2 Roles and Responsibilities
ISO 27001 Clause 5.3 Organisational Roles, Responsibilities and Authorities
ISO 27001 Clause 7.2 Competence
Further Reading
ISO 27001 Annex A 5.4 for Small Business
ISO 27001 Annex A 5.4 for Tech Startups
ISO 27001 Annex A 5.4 for Ai Companies
ISO 27001 Competency Matrix Beginner’s Guide
ISO 27001 Controls and Attribute Values
| Control type | Information security properties | Cybersecurity concepts | Operational capabilities | Security domains |
|---|---|---|---|---|
| Preventive | Confidentiality | Identify | Governance | Governance and Ecosystem |
| Integrity | ||||
| Availability |
