In this guide, I will show you exactly how to implement ISO 27001 Annex A 5.9 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 5.9 Inventory of Information and Other Associated Assets
ISO 27001 Annex A 5.9 requires organizations to develop and maintain an inventory of all information and other associated assets, including the assignment of owners. This control is based on a simple but critical security principle: “You cannot protect what you do not know.” By identifying every physical device, software application, and data set within your scope, you create the foundation for risk management, incident response, and lifecycle management.
Core requirements for compliance include:
- Identification of 3 Asset Types: You must inventory three specific categories:
- Physical Assets: Laptops, servers, networking hardware, and removable media.
- Information/Data Assets: Customer databases, intellectual property, financial records, and source code.
- Virtual Assets: Cloud instances, virtual machines (VMs), and software-as-a-service (SaaS) subscriptions.
- Assignment of Ownership: Every asset must have an assigned “Owner.” The owner is responsible for ensuring the asset is correctly classified, reviewed periodically, and securely disposed of at the end of its life.
- Accuracy and Consistency: The inventory must be a “living document.” It must be updated whenever new assets are created, transferred, or decommissioned.
- Location Tracking: You must record where assets are located, whether in a physical office, a specific data center, or a cloud region.
- Asset Classification: Each asset in the inventory should be linked to your Information Classification scheme (e.g., Public, Internal, Confidential).
Audit Focus: Auditors will look for “The Ghost Asset”:
- Sample Verification: An auditor will pick a random laptop in the office and ask: “Show me this device in your Physical Asset Register. Who is the owner?”
- SaaS/Cloud Shadow IT: “How do you ensure that a new SaaS tool purchased by the Marketing department is added to your Information Asset Register?”
- Termination Check: “When an employee leaves, how do you use the asset inventory to ensure 100% of their physical and virtual assets are returned or revoked?”
Asset Register Components (Audit Prep):
| Asset Category | Example Items | Required Evidence | ISO 27001 Action | ISO 27001:2022 Control |
|---|---|---|---|---|
| Physical | Laptops, Servers, USBs. | Serial Number, Location. | Physical Security (A.7). | Annex A 7.1, 7.10 |
| Information | Customer DB, Source Code. | Data Classification level. | Access Control (A.5.15). | Annex A 5.12, 5.15 |
| Virtual | AWS Instances, SaaS Tools. | Instance ID, Admin Owner. | Cloud Security (A.5.23). | Annex A 5.23, 8.15 |
| Software | OS, Licensed Apps. | Version, License Expiry. | Configuration (A.8.9). | Annex A 8.9, 8.19 |
Table of contents
- What is ISO 27001 Annex A 5.9?
- Watch the ISO 27001 Annex A 5.9 Tutorial
- ISO 27001 Annex A 5.9 Podcast
- ISO 27001 Annex A 5.9 Implementation Guidance
- How to implement ISO 27001 Annex A 5.9
- ISO 27001 Templates
- How to comply
- How to pass the ISO 27001 Annex A 5.9 audit
- What will an audit check?
- Top 3 ISO 27001 Annex A 5.9 Mistakes People Make and How to Avoid Them
- Applicability of ISO 27001 Annex A 5.9 across different business models.
- Fast Track ISO 27001 Annex A 5.9 Compliance with the ISO 27001 Toolkit
- ISO 27001 Annex A 5.9 FAQ
- Further Reading
- ISO 27001 Controls and Attribute Values
What is ISO 27001 Annex A 5.9?
ISO 27001 Annex A 5.9 is about inventory of assets which means you need to have a list of the physical and information assets that you have so you know what needs to be protected.
ISO 27001 Annex A 5.9 Inventory of Information and Other Associated Assets is an ISO 27001 control that requires an organisation to develop and maintain an inventory of information and other associated assets.
We cannot control what we do not know so this clause is about understanding our data and the assets that process, store or transmit it.
ISO 27001 Annex A 5.9 Purpose
The purpose of ISO 27001 Annex A 5.9 is to ensure you identify the organisations information and other associated assets in order to preserve their information security and assign appropriate ownership.
ISO 27001 Annex A 5.9 Definition
The ISO 27001 standard defines ISO 27001 Annex A 5.9 as:
An inventory of information and other associated assets, including owners, should be developed and maintained.
ISO 27001:2022 Annex A 5.9 Inventory of information and other associated assets
Watch the ISO 27001 Annex A 5.9 Tutorial
In the video ISO 27001 Annex A 5.9 Inventory Of Information And Other Associated Assets Explained show you how to implement it and how to pass the audit.
ISO 27001 Annex A 5.9 Podcast
In this episode: Lead Auditor Stuart Barker and team do a deep dive into the ISO 27001 Annex A 5.9 Inventory Of Information And Other Associated Assets. The podcast explores what it is, why it is important and the path to compliance.
ISO 27001 Annex A 5.9 Implementation Guidance
You are going to have to ensure that
- information and assets are identified
- the importance of information and assets is determined
- information and assets are documented
- documentation is accurate, up to date and consistent
- the location of assets is recorded
- assets are classified
- ownership of assets is allocated when created or transferred to the organisation and reassigned when current owners leave or change role
Topic specific policy on asset management
You are going to implement a topic specific policy on asset management. You can learn more in our Beginner’s Guide to the Asset Management Policy.
Data Asset Register
You will implement a Data Asset Register.
Physical Asset Register
You will implement a Physical Asset Register that will include virtual machines. You can learn more in our Beginner’s Guide to the Physical Asset Register.
Return of assets
You will implement a process for the return of assets in line with the guidance in ISO 27001 Annex A 5.11 Return of Assets
Acceptable use of assets
You will implement a process for the acceptable use of assets in line with the guidance in ISO 27001 Annex A 5.10 Acceptable use of information and other associated assets.
What about virtual machines?
The standard has been updated to account for virtual machines. It sets out that the level of detail required should be appropriate of the needs of the organisation.
Sometimes it just isn’t feasible to document instances of virtual machines especially if they are short lived as is the case with some virtual machines that can be short lived and have a short duration. That is ok.
Asset Ownership
Assets need to be assigned an owner. The standard allows for ownership to be individuals or groups. Where possible you should try to identify individuals. This can be either named individuals or the job title of the role. By allocating to an individual it will drive more accountability than assigning to a group of people.
What are asset owners duties?
The asset owner is going to be responsible for the management and protection of the asset over its entire lifecycle. They are going to
- Make sure assets are document and in asset registers
- Ensure assets have the correct classification and protection
- Review assets and set intervals which will include access to the asset and the controls protecting the asset
- Put in place the acceptable use requirements for the asset
- Be responsible for the correct deletion / disposal of the asset and the documentation recording it including removing from asset registers.
- Be part of the risk identification and risk management of the assets
How to implement ISO 27001 Annex A 5.9
Implementing ISO 27001 Annex A 5.11 requires a transition from informal equipment hand-ins to a rigorous, policy-driven offboarding framework. By synchronising HR termination triggers with IT asset recovery protocols, organisations mitigate the risk of data leakage and unauthorised retention of proprietary hardware. This technical guide outlines the action-oriented steps to formalise your return of assets process and satisfy lead auditor requirements for the 2022 standard.
1. Formalise the Asset Management Policy and Scope
Establish a documented policy that defines what constitutes an “asset” within your organisation. This action results in a standardised governance layer that ensures all digital, physical, and intangible assets are captured within the Information Security Management System (ISMS).
- Define asset categories including Information, Software, Physical, and Services (Cloud/SaaS).
- Document the mandatory fields for the inventory, such as classification level, location, and asset type.
- Establish “Rules of Engagement” (ROE) for how new assets must be registered before being provisioned to users.
2. Provision a Centralised Information Asset Register (IAR)
Execute a discovery phase to identify all information-bearing assets and centralise them into a single, master inventory. This result-focused step eliminates data silos and provides a baseline for the subsequent risk assessment process.
- Utilise automated discovery tools to scan the network for unauthorised “shadow IT” hardware and cloud instances.
- Map information assets to the underlying physical or virtual infrastructure they reside on.
- Log essential technical metadata including serial numbers, MAC addresses, and software versioning.
3. Formalise Asset Ownership and Accountability
Assign every asset in the inventory to a specific “Asset Owner” who is responsible for its protection. This action ensures that accountability is distributed across the business rather than being centralised solely within the IT department.
- Document the specific responsibilities of the Asset Owner, including periodic classification reviews and access authorisation.
- Map Asset Owners to specific departments or IAM roles to ensure ownership remains current during internal transfers.
- Incorporate asset ownership into the “Joiner, Mover, Leaver” (JML) workflow to prevent assets from becoming orphaned.
4. Implement Technical Mapping of Asset Dependencies
Document the relationships between different assets to understand how a failure in one impacts the security of others. This action results in a technically dense view of your infrastructure that is critical for business continuity and disaster recovery.
- Identify which software applications process specific sensitive datasets.
- Map physical hardware to the cloud services or databases they interact with via API or direct connection.
- Maintain a Configuration Management Database (CMDB) to track the technical dependencies that support critical business processes.
5. Execute Periodic Inventory Audits and Recertification
Perform regular reviews of the inventory to verify the continued existence, ownership, and classification of every asset. This result-orientated step ensures that the Asset Register remains a “living document” that accurately reflects the organisational risk profile.
- Schedule annual physical inspections for high-value hardware assets.
- Require Asset Owners to perform a quarterly digital sign-off on the accuracy of their assigned assets.
- Update the inventory immediately following the decommissioning or disposal of any hardware to maintain an accurate audit trail.
ISO 27001 Templates
You can save months of effort and do it yourself with the ISO 27001 Toolkit that take 25 years of experience and distill it in a pack of prewritten best practice awesomeness.
If you would rather have individual topic specific templates then consider
How to comply
To comply with ISO 27001 Annex A 5.9 Inventory of information and other associated assets you are going to implement the ‘how’ to the ‘what’ the control is expecting. In short measure you are going to:
- Establish and document asset inventories
- Identify, list and document the assets
- Assign owners to assets
- Protect and ensure adequate controls for assets based on risk and classification
- Review asset inventories and access to assets
How to pass the ISO 27001 Annex A 5.9 audit
To pass an audit of ISO 27001 Annex A 5.9 Inventory of information and other associated assets you are going to make sure that you have followed the steps above in how to comply.
What will an audit check?
The audit is going to check a number of areas. Lets go through the main ones
1. That you have an inventory of assets
What this means is that you need to show that you have asset inventories in place. It does not need to be one inventory but every asset must be in an inventory.
2. That you have taken action as a result of asset inventories
Your asset registers and asset inventories are going to be living documents with asset owners documented and assigned and the key controls and required components of the registers recorded. The audit will check that reviews are performed and that access to assets has been performed. It will check the implemented and documented controls that protect those assets.
3. That asset inventory forms part of risk management and operations
Your asset register will factor in and evidence risk management. This could be management of the risks associated with assets or the risks that the assets themselves pose.
Top 3 ISO 27001 Annex A 5.9 Mistakes People Make and How to Avoid Them
The top 3 Mistakes People Make For ISO 27001 Annex A 5.9 are
1. Your asset register and asset inventory does not include all assets
Remembering the scope is the scope statement and your ISO 27001 scope it is easy to focus on data assets that relate to data protection and miss the wider data assets. Code repositories are a good example. Focusing on productions assets and not considering development and test. Stating that VMS are not assets or are too hard to manage and document.
2. You do not evidence ownership or actions
Be sure owners are assigned and that actions such as access reviews and asset reviews can be evidenced. Do not overlook end of life processes, destruction of assets or when asset owners leave or change role.
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 5.9 across different business models.
| Business Type | Applicability & Interpretation | Examples of Control |
|---|---|---|
| Small Businesses |
Physical & Data Lists. You likely don’t need automated discovery tools. Compliance is achieved by maintaining a simple Excel “Asset Register” listing laptops and key folders (e.g., “HR Sharepoint”). |
• The Laptop List: A spreadsheet tracking Serial Numbers, assigned Owners, and Return Dates for all physical hardware. |
| Tech Startups |
Virtual & SaaS Inventory. Your assets are mostly in the cloud. Auditors expect an inventory of “Virtual Assets” (AWS Instances, S3 Buckets) and “SaaS Subscriptions” to prevent Shadow IT. |
• Cloud Tagging: Using AWS/Azure Resource Tags (e.g., |
| AI Companies |
Model & Dataset Provenance. Assets include intangible IP. You must inventory not just code, but specific “Model Checkpoints,” “Training Datasets,” and “API Keys” as distinct assets. |
• Model Registry: A catalog listing every deployed model version (e.g., v1.2), its training data source, and the responsible Data Scientist. |
Fast Track ISO 27001 Annex A 5.9 Compliance with the ISO 27001 Toolkit
For ISO 27001 Annex A 5.9 (Inventory of information and other associated assets), the requirement is to develop and maintain an inventory of all physical and information assets, including their owners. This is the foundation of your entire security system, you cannot protect what you do not know you have.
| Compliance Factor | SaaS Compliance Platforms | High Table ISO 27001 Toolkit | Audit Evidence Example |
|---|---|---|---|
| Inventory Ownership | Rents access to your asset records; if you cancel the subscription, your documented asset history and ownership logs vanish. | Permanent Assets: Fully editable Word/Excel Data and Physical Asset Registers that you own and host forever. | A localized “Physical Asset Register” containing serial numbers, purchase dates, and assigned hardware owners. |
| Governance Utility | Attempts to “automate” discovery via APIs that cannot assign accountability or ensure virtual machines are correctly classified. | Governance-First: Provides the framework to formalize existing technical lists (AWS, Azure) into an auditor-ready format. | A “Data Asset Register” proving that critical datasets (e.g., Customer DB) have been identified and assigned to a C-level owner. |
| Cost Efficiency | Charges an “Asset Count Tax” or “Node Fee” that scales costs aggressively as your infrastructure and data sets expand. | One-Off Fee: A single payment covers your inventory governance for 10 assets or 10,000, with zero recurring overhead. | Allocating budget to actual infrastructure security rather than monthly “compliance dashboard” fees for simple list-making. |
| Strategic Freedom | Mandates rigid categorization formats that often fail to align with unique data structures or specialized virtual environments. | 100% Agnostic: Procedures adapt to your environment—from high-density data centers to purely virtual, remote-first teams. | The ability to evolve your asset management strategy (e.g., adding lifecycle destruction logs) without a rigid SaaS middleman. |
Summary: For Annex A 5.9, the auditor wants to see that you have a formal inventory of all assets and that owners have been assigned to each one. 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 5.9 FAQ
What is ISO 27001 Annex A 5.9?
ISO 27001 Annex A 5.9 is an organisational control that requires an organisation to identify and maintain an inventory of information and other associated assets to ensure continued protection.
- Mandates the creation of a formal Asset Register.
- Includes digital data, physical hardware, software, and intangible assets.
- Requires assets to be accurately categorised and assigned to an owner.
- Ensures the organisation understands its attack surface and risk profile.
Is an Asset Register mandatory for ISO 27001?
Yes, maintaining an accurate inventory of information assets is a mandatory requirement for ISO 27001:2022 compliance under control 5.9.
- Auditors will expect to see a documented Information Asset Register (IAR).
- Failure to track assets is often cited as a major non-conformity.
- It serves as the foundation for Annex A 5.12 (Classification) and Annex A 5.10 (Acceptable Use).
- Without an inventory, an organisation cannot prove it has identified all relevant security risks.
What items should be included in an ISO 27001 inventory?
An ISO 27001 inventory must include all assets that store, process, or transmit sensitive organisational information.
- Information Assets: Databases, system documentation, and intellectual property.
- Software Assets: Application software, system software, and development tools.
- Physical Assets: Laptops, servers, mobile devices, and removable media.
- Services: Cloud services (SaaS/PaaS) and outsourced utilities.
Who is responsible for the inventory of assets?
The ultimate responsibility for maintaining the inventory lies with the organisation, but day-to-day accountability is assigned to individual Asset Owners.
- Management must ensure that roles and responsibilities are clearly defined.
- Asset Owners are responsible for the classification and protection of their assigned assets.
- IT teams typically manage the technical tracking of hardware and software.
- Compliance officers ensure the inventory is reviewed and updated periodically.
How often should an Information Asset Register be updated?
The Asset Register should be updated in real-time as assets are commissioned or decommissioned, with a formal review occurring at least annually.
- Changes should be captured during the “Joiner, Mover, Leaver” (JML) process.
- Updates are required following major infrastructure changes or software migrations.
- Quarterly reviews are considered best practice for high-growth organisations.
- Annual audits ensure that “shadow IT” or orphaned assets are identified and removed.
What is the difference between an Asset Register and a Configuration Management Database (CMDB)?
The primary difference is that an Asset Register focuses on ownership and security value (ISO 27001), while a CMDB focuses on technical relationships and service management (ITIL).
- Asset Register: Tracks who owns the data and its classification level.
- CMDB: Tracks how a server connects to a database and its technical configuration.
- Integration: Many organisations use their CMDB to automatically populate the technical portions of their Asset Register.
Further Reading
How to Implement ISO 27001:2022 Annex A 5.9: Inventory of Information and Other Associated Assets
How to Audit ISO 27001:2022 Annex A 5.9: Inventory of Information and Other Associated Assets
ISO 27001 Return of Assets Beginner’s Guide
ISO 27001:2022 Annex A 5.9 for Small Business: You Can’t Protect What You Can’t See
ISO 27001:2022 Annex A 5.9 for AI Companies: Where Are Your Models?
ISO 27001:2022 Annex A 5.9 for Tech Startups: Taming the SaaS Chaos
ISO 27001 Controls and Attribute Values
| Control type | Information security properties | Cybersecurity concepts | Operational capabilities | Security domains |
|---|---|---|---|---|
| Preventive | Confidentiality | Identify | Asset management | Governance and Ecosystem |
| Integrity | Protection | |||
| Availability |
