In this guide, I will show you exactly how to implement ISO 27001 Annex A 8.30 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 8.30 Outsourced Development
ISO 27001 Annex A 8.30 requires that if you hire third-party developers (agencies, freelancers, or offshore teams) to build software for you, you must supervise their security standards. You cannot simply trust them to “do a good job.” You must define your security requirements in the contract and verify they are met before accepting the final code.
Core requirements for compliance include:
- Contractual Security: The contract must explicitly state your security expectations (e.g., “Must follow OWASP Top 10 guidelines,” “Must not use GPL libraries,” “Must encrypt all data”).
- Supervision & Monitoring: You need a process to check their work during the project, not just at the end. This might include regular code reviews or requiring them to submit vulnerability scan reports with each milestone.
- Testing / Acceptance: You must test the outsourced code yourself (or hire a third party to do it) before it goes live. Never blindly deploy code sent by a vendor.
- IP & Licensing: Clarify who owns the code and ensure the vendor isn’t using pirated or restrictive open-source components that could legally endanger your product.
Audit Focus: Auditors will ask: “How do you know the freelancer didn’t leave a backdoor in the code?”
- The Contract: They will check if your “Services Agreement” includes a security schedule or clause.
- The Evidence: They will ask for the Penetration Test Report or Code Scan you ran on the vendor’s deliverable before you paid the final invoice.
- The Supply Chain: They will check if you performed “Due Diligence” (e.g., a questionnaire) before hiring the dev shop.
In-House vs. Outsourced Responsibilities:
| Task | In-House Devs | Outsourced Devs | ISO 27001:2022 Control |
|---|---|---|---|
| Security Standards | Follow Internal Policy. | Must be written in the Contract. | Annex A 5.10 & 8.30 |
| Code Review | Peer review by colleagues. | Review by YOU (the client) before acceptance. | Annex A 8.28 & 8.30 |
| Environment | Managed by IT Team. | Managed by Vendor (Audited by YOU). | Annex A 8.31 |
| Accountability | Employee Disciplinary process. | Contractual Penalty / Termination. | Annex A 5.20 |
Table of contents
- Key Takeaways: ISO 27001 Annex A 8.30 Outsourced Development
- What is ISO 27001 Annex A 8.30?
- ISO 27001 Annex A 8.30 Explainer Video
- ISO 27001 Annex A 8.30 Podcast
- How to implement ISO 27001 Annex A 8.30
- ISO 27001 Annex A 8.30 Implementation Checklist
- ISO 27001 Annex A 8.30 Audit Checklist
- Applicability of ISO 27001 Annex A 8.30 across different business models.
- Fast Track ISO 27001 Annex A 8.30 Compliance with the ISO 27001 Toolkit
- Conclusion
- ISO 27001 Annex A 8.30 FAQ
- Related ISO 27001 Controls
- Further Reading
What is ISO 27001 Annex A 8.30?
ISO 27001 Annex A 8.30 Outsourced Development is an ISO 27001 control that requires an organisation to make sure that outsourced developments are meeting organisational information security requirements.
ISO 27001 Annex A 8.30 Purpose
ISO 27001 Annex A 8.26 is a preventive control and a detective control to ensure information security measures required by the organisation are implemented in outsourced system development.
ISO 27001 Annex A 8.30 Definition
ISO 27001 defines ISO 27001 Annex A 8.30 as:
The organisation should direct, monitor and review the activities related to outsourced system development.
ISO27001:2022 Annex A 8.30 Outsourced Development
ISO 27001 Annex A 8.30 Explainer Video
In this strategic implementation briefing, Lead Auditor Stuart Barker and team do a deep dive into ISO 27001:2022 Annex A 8.30 Outsourced Development.
ISO 27001 Annex A 8.30 Podcast
In this episode: Lead Auditor Stuart Barker and team do a deep dive into the ISO 27001:2022 Annex A 8.30 Outsourced Development. The podcast explores what it is, why it is important and the path to compliance.
How to implement ISO 27001 Annex A 8.30
This is all about managing your outsourced development and making sure that it, and they, are following your requirements for information security. This will be done by telling them what you expect, getting it into agreements such as contracts and then regularly reviewing and monitoring them to ensure that it is being done.
In addition, we treat the developers as a third party for which the following will apply:
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 5.22 Monitor, Review And Change Management Of Supplier Services
Securing outsourced development requires a rigorous framework to ensure third-party vendors adhere to your organization’s internal security standards. By following these technical implementation steps, you can mitigate the risks of supply chain attacks and maintain compliance with ISO 27001 Annex A 8.30.
1. Formalize Contractual Security Obligations
- Draft a Master Service Agreement (MSA) or Statement of Work (SOW) that explicitly mandates adherence to ISO 27001 secure coding standards.
- Incorporate Right-to-Audit (RTA) clauses and specific Service Level Agreements (SLAs) for vulnerability remediation timelines.
- Result: Establishing a legally binding baseline for security performance and accountability.
2. Standardize Secure Coding and SDLC Requirements
- Provide the external vendor with a documented Secure Software Development Life Cycle (SDLC) framework, including OWASP Top 10 mitigation strategies.
- Define technical requirements for input validation, cryptography, and error handling to be used throughout the development process.
- Result: Ensuring the delivered code is resilient against common web and application vulnerabilities.
3. Provision Granular Access Control via IAM and MFA
- Establish dedicated Identity and Access Management (IAM) roles for external developers with “Least Privilege” permissions.
- Enforce Multi-Factor Authentication (MFA) and utilize Zero Trust Architecture (ZTA) or encrypted VPNs for all development environment access.
- Result: Preventing unauthorized lateral movement within your infrastructure by third-party entities.
4. Validate Code Integrity via SAST and DAST
- Integrate Static Application Security Testing (SAST) and Dynamic Application Security Testing (DAST) tools into the CI/CD pipeline for all outsourced builds.
- Mandate manual peer reviews of external code by internal security architects before any merge to the main branch.
- Result: Identifying and neutralizing security flaws and “backdoors” before code enters production.
5. Execute Rigorous Acceptance Testing and Auditing
- Conduct User Acceptance Testing (UAT) in an isolated staging environment to verify that security controls function as specified.
- Perform independent penetration testing or vulnerability scans on the final deliverables prior to deployment.
- Result: Verifying that the final product meets all functional and security specifications of ISO 27001.
6. Secure Intellectual Property and Environment De-provisioning
- Implement automated scripts to revoke all vendor access tokens, SSH keys, and IAM credentials immediately upon project completion or termination.
- Ensure all intellectual property, including source code and documentation, is transferred to secure internal repositories.
- Result: Eliminating residual risk and “orphaned” accounts following the conclusion of the outsourced engagement.
If you outsource your development then the third party supplier controls will apply. The main thing is to ensure they meet your requirements for secure development but all relevant controls that apply to you, will apply to them.
ISO 27001 Annex A 8.30 Implementation Checklist
ISO 27001 Annex A 8.30 Outsourced Development Implementation Checklist:
1. Vendor Selection and Due Diligence
Conduct thorough due diligence on potential outsourced developers, assessing their information security posture, certifications (e.g., ISO 27001, SOC 2), and track record. Include security requirements in supplier selection criteria and RFPs.
Challenges: Limited vendor transparency, difficulty evaluating vendor claims.
Solutions: Third-party audits, detailed security questionnaires, reference checks.
2. Contractual Agreements
Include comprehensive security clauses in all contracts with outsourced development vendors, defining responsibilities, liabilities, and obligations related to information security.
Challenges: Negotiating strong contracts, enforcing contractual obligations.
Solutions: Legal counsel, regular contract reviews, dispute resolution mechanisms.
3. Information Sharing & Access Controls
Implementation: Establish secure procedures for sharing sensitive information with vendors, implement robust access controls, and utilise secure communication channels.
Challenges: Data breaches, insider threats.
Solutions: Data Loss Prevention (DLP) tools, security awareness training, background checks.
4. Data Protection & Privacy
Ensure compliance with relevant data protection regulations (e.g., GDPR) when sharing data with outsourced developers. Implement appropriate data protection measures, such as data masking and encryption.
Challenges: Meeting evolving data privacy regulations, ensuring vendor compliance.
Solutions: Data processing agreements, regular privacy impact assessments, ongoing supplier monitoring.
5. Incident Management
Establish clear incident reporting procedures, develop a joint incident response plan with vendors, and conduct regular incident response drills.
Challenges: Timely incident detection and response, coordination with vendors.
Solutions: Security Information and Event Management (SIEM) systems, automated incident response tools, clear communication procedures.
6. Physical and Environmental Security
Ensure that vendors maintain adequate physical and environmental security measures, including secure facilities, access controls, and environmental controls.
Challenges: Assessing and verifying vendor physical security measures.
Solutions: On-site audits, remote monitoring of security systems, third-party security assessments.
7. Human Resources Security
Ensure that vendors have robust HR security practices, including background checks, employee security training, and secure employee onboarding and off-boarding procedures.
Challenges: Ensuring compliance with vendor HR security practices.
Solutions: Contractual requirements, regular vendor assessments, third-party HR security audits.
8. System and Application Security
Ensure that vendors have robust systems and application security controls, including secure development practices, vulnerability management, and regular security testing.
Challenges: Assessing the security of complex systems and applications.
Solutions: Penetration testing, vulnerability assessments, code reviews, secure development lifecycle (SDLC) processes.
9. Business Continuity and Disaster Recovery
Ensure that vendors have business continuity and disaster recovery plans in place to minimise the impact of disruptions on outsourced services.
Challenges: Verifying the effectiveness of vendor BCP/DR plans.
Solutions: Business impact analysis, disaster recovery drills, regular review and updates of BCP/DR plans.
10. Continuous Monitoring & Improvement
Conduct regular security audits and assessments of outsourced development activities, monitor vendor performance against agreed-upon security controls and KPIs, and continuously improve security processes.
Challenges: Maintaining visibility into vendor security practices, resource constraints.
Solutions: Third-party audits, automated monitoring tools, regular review and improvement of security controls.
ISO 27001 Annex A 8.30 Audit Checklist
ISO 27001 Annex A 8.30 Outsourced Development Audit Checklist
1. Outsourced Developer Management
Evidence that the guidance in the following was followed:
- 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 5.22 Monitor, Review And Change Management Of Supplier Services
2. Vendor Selection and Due Diligence
- Assess the process for selection the outsourced developer
- Review the due diligence that was carried out.
- Seek evidence of vendor security certifications and / or audits and / or questionnaires.
- Review a sample of supplier references.
3. Contractual Agreements
Check contracts in place and that they cover
- the products and services the organisation has aquired
- clauses for information security
Assess if contracts were reviewed and approved by legal counsel
Ensure that regular contractual reviews are in place and evidenced.
4. Information Sharing & Access Controls
Have secure procedures for sharing sensitive information with been establised.
Are access controls and user access lifecycle management in place.
5. Data Protection & Privacy
Ensure compliance with relevant data protection regulations (e.g., GDPR) when sharing data with outsourced developers is in place.
Walkthrough the processes and procedures.
6. Incident Management
Assess the incident management process and communication channels with the outsourced developer.
7. Physical and Environmental Security
Audit to ensure that the outsourced developers maintain adequate physical and environmental security measures, including secure facilities, access controls, and environmental controls.
8. Human Resources Security
With your HR team review if vendors have robust HR security practices, including background checks, employee training, and secure employee onboarding and off-boarding procedures.
Assess contracts for requirements.
9. System and Application Security
Walkthrough and asses that vendors have robust systems and application security controls, including secure development practices, vulnerability management, and regular security testing.
Seek evidence of penetration testing, vulnerability assessments, code reviews, secure development lifecycle (SDLC) processes.
10. Business Continuity and Disaster Recovery
Review the business continuity and disaster recovery plans and check that they minimise the impact of disruptions on outsourced services.
Assess the outsourced developers business impact analysis, disaster recovery plans, regular review and updates of BCP/DR plans.
11. Continuous Monitoring & Improvement
Check any security audits and assessments of outsourced development activities.
Review if there is a monitor of supplier performance against agreed-upon security controls and KPIs, and if they continuously improve security processes.
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Applicability of ISO 27001 Annex A 8.30 across different business models.
| Business Type | Applicability | Examples of Control Implementation |
|---|---|---|
| Small Businesses | Typically applies when outsourcing website design, e-commerce maintenance, or bespoke internal tools to digital agencies or freelancers. Focus is on contractual basics and acceptance testing. |
|
| Tech Startups | Crucial when using offshore teams to accelerate MVP development or build mobile app variants. Focus is on integration with SDLC, CI/CD pipelines, and rigorous code review. |
|
| AI Companies | Applies to outsourcing data labeling platforms, frontend interfaces for models, or specific algorithm optimization. Focus is on IP protection, data security, and input validation. |
|
Fast Track ISO 27001 Annex A 8.30 Compliance with the ISO 27001 Toolkit
For ISO 27001 Annex A 8.30 (Outsourced development), the requirement is fundamentally about contractual control and assurance, ensuring that your third-party developers follow the same security rules you do. This is a legal and procedural challenge, not a software feature.
| Compliance Factor | SaaS Vendor Management (VRM) | High Table ISO 27001 Toolkit | Real-World Example |
|---|---|---|---|
| Data Ownership & Continuity | Stores risk assessments in proprietary formats. If you leave the platform, you often lose the audit trail proving you vetted developers. | Permanent Ownership: You receive standard Word/Excel formats (Supplier Security Policy) that reside on your system forever. | Retaining legal text protecting IP and risk assessments without maintaining a subscription. |
| Simplicity & Workflow | Overcomplicates compliance by forcing external agencies to log into specialized portals to upload certificates. | Direct & Actionable: Provides “Supplier Security Questionnaires” and “Development Agreements” you can email directly. | Sending a checklist via email to a developer rather than requiring them to learn new software. |
| Cost Structure | Often charges on a “per-vendor” basis. Costs escalate quickly if you use multiple freelancers or agencies. | One-Off Fee: A single payment covers the entire governance suite regardless of how many vendors you manage. | Applying the “Secure Development Policy” to 10 different agencies for zero additional cost. |
| Flexibility & Customization | Forces you into rigid scoring models or “red flag” systems that may not fit gig workers or long-term partners. | Total Freedom: Fully editable policies allow you to define security requirements that match the specific relationship. | Tailoring the “Outsourced Development Policy” for a single local contractor vs. a massive offshore team. |
Summary: For Annex A 8.30, the auditor wants to see that you have legally bound your developers to your security standards. The High Table ISO 27001 Toolkit provides the governance framework to do exactly that, giving you the policies, contract clauses, and checklists to manage external code risks effectively, without the ongoing cost of a SaaS subscription.
Conclusion
Many if not all of the controls that apply to this control are covered elsewhere. Be it the experience, licensing, technical controls but consider them in the context of this clause and be able to evidence them as they apply to outsourced development.
ISO 27001 Annex A 8.30 FAQ
What is the primary requirement of ISO 27001 Annex A 8.30?
ISO 27001 Annex A 8.30 requires that organizations supervise and monitor all outsourced software development to ensuring security requirements are met. You cannot simply “trust” a vendor to build secure code; you must define security standards in the contract and verify they are followed throughout the development lifecycle.
What should be included in an outsourced development contract?
Contracts must go beyond functionality and explicitly define security obligations and the right to audit. To comply with Control 8.30, your agreement should specify:
- Secure Coding Standards: The vendor must follow specific guidelines (e.g., OWASP Top 10) to prevent vulnerabilities.
- Testing Requirements: Mandating Static (SAST) and Dynamic (DAST) application security testing prior to delivery.
- Right to Audit: Your organization’s right to review their code, architecture, or security logs.
- Intellectual Property: Clarity on who owns the code and who is responsible for fixing security bugs discovered post-launch.
How do we monitor compliance for outsourced code?
Monitoring must be active and evidence-based, occurring at milestones rather than just at final delivery. Effective supervision methods include:
- Regular Code Reviews: Requesting access to the repository to spot-check code quality and security practices.
- vCISO / Security Reviews: Having your security team review the proposed architecture before coding begins (Security by Design).
- Testing Evidence: Requiring the vendor to submit reports from their vulnerability scans before you accept the software.
Does this control apply to freelancers and off-the-shelf software?
It applies strictly to custom development (outsourced coding), regardless of whether it is a freelancer or a large agency.
- Freelancers/Agencies: Yes. If they are writing code specifically for you, Control 8.30 applies.
- COTS (Commercial Off-The-Shelf): Generally No. Buying standard software (like Microsoft Office) falls under Supplier Relationships (5.19), specifically “Information security in supplier relationships,” rather than outsourced development.
What will an ISO 27001 auditor ask regarding Control 8.30?
Auditors will look for evidence that you managed the security risk, rather than just the timeline or budget. Expect questions such as:
- “Show me the contract where you defined the security requirements for this project.”
- “How did you verify the developer followed your secure coding guidelines?”
- “Did you scan the delivered code for malware or vulnerabilities before deploying it to production?”
- “Show me the acceptance criteria you used to sign off on the security of this release.”
What is the difference between Control 8.30 and Supplier Relationships (5.19)?
Control 8.30 is specific to the creation of software, while Control 5.19 covers the general business relationship.
- Annex A 5.19 (Supplier Relationships): Focuses on the contract, access management, and general service delivery (e.g., “Do they have ISO 27001 certification?”).
- Annex A 8.30 (Outsourced Development): Focuses on the product being built (e.g., “Did they sanitize inputs to prevent SQL injection?” or “Did they remove hardcoded passwords?”).
Related ISO 27001 Controls
ISO 27001 Monitoring, Measurement, Analysis, Evaluation: Clause 9.1
ISO 27001 Secure Systems Architecture and Engineering Principles: Annex A 8.27
ISO 27001 Security Testing in Development and Acceptance: Annex A 8.29
Further Reading
ISO 27001 Supplier Register Beginner’s Guide
ISO 27001 Secure Development Policy Template
ISO 27001 Patch Management Policy Beginner’s Guide
