ISO 27001 transition: why businesses must meet new requirements before October 31st 2025

The ISO 27001 transition deadline is fast approaching, meaning all ISO 27001:2013 certifications will soon be outdated, requiring replacement with the ISO 27001:2022 standard.

While not a legal requirement for all, many UK businesses must maintain ISO 27001 certification to meet industry regulations, customer expectations, or contractual obligations. Businesses that do not complete the transition by the 31st of October 2025 will lose their ISO 27001:2013 certification and must begin the process again to regain compliance.

However, this transition is about more than just compliance; it’s about strengthening your organisation’s defences against future cyber threats. In this article, we’ll look at what ISO 27001:2022 is, why the transition is necessary, the key changes from ISO 27001:2013, the risks of not achieving the new certification before the deadline, and how Net-Defence can help.

What is ISO 27001:2022?

ISO 27001:2022 is an internationally recognised standard for information security management systems (ISMS). This standard ensures that UK businesses maintain compliance with government regulations, stay up to date with modern cyber security practices, and continue to improve their information security framework.

It provides a comprehensive and structured framework for organisations to manage and protect sensitive information from a variety of security threats. It gives a standard guideline to help organisations better understand how to identify and assess potential security risks, ensuring that adequate safeguards are in place to protect data confidentiality, integrity, and availability.

By following these guidelines, organisations can establish, implement, maintain, and continually improve an ISMS that aligns with business goals, legal requirements, and industry best practices.

Why is the ISO 27001 transition necessary for businesses?

Businesses are required to transition from ISO 27001:2013 to ISO 27001:2022 for several reasons. These include:

Evolving cyber threats

Cyberattacks are evolving every day, becoming more sophisticated, and posing new risks to businesses through advanced tactics such as ransomware, phishing, and supply chain attacks.

To address these modern risks, ISO 27001:2022 includes updated controls such as threat intelligence, web filtering, and data masking to assist businesses in detecting, preventing, and mitigating modern, evolving threats.

Cloud and remote working growth

Since 2013, the widespread adoption of cloud services and the shift to hybrid working have changed the way businesses operate. Employees are increasingly accessing company systems from a variety of locations and devices, raising the risk of data breaches and unauthorised access.

To reflect these changes, ISO 27001:2022 puts greater emphasis on secure cloud configurations, enhancing remote access controls, and strengthening user authentication.

These updates help organisations in protecting sensitive data in dispersed work environments and mitigating vulnerabilities associated with cloud-based operations.

Emphasis on emerging technologies

ISO 27001:2022 provides updated guidance on securing modern technologies, which are increasingly integrated into business operations.

This includes improved safeguards for protecting Internet of Things (IoT) devices, which are frequently vulnerable due to insufficient security controls, as well as AI systems, where data integrity and algorithm manipulation pose unique threats.

What are some of the key updates?

The 2022 revision of ISO 27001 introduces several key updates to help businesses improve their security practices. These include:

A strengthened approach to proactive risk management

The revised standard places a stronger focus on proactive risk management, requiring organisations to make an on-going commitment to identify, assess, and mitigate potential security risks rather than simply reacting to incidents.

These new regulations encourage businesses to move away from generic, one-size-fits-all controls and towards a more tailored approach to security. Organisations can address emerging threats more effectively by identifying risks specific to their industry, operations, and digital environment.

This tailored approach improves critical information protection and ensures that security strategies align with an organisation’s specific risk profile.

Streamlined implementation of Annex A

ISO 27001:2022 revised the structure of Annex A, a comprehensive list of controls that organisations can implement to address security risks. This new structure introduces a more streamlined and practical approach to implementing security controls.

It has accomplished this by creating clearer categories and reducing the number of controls from 114 to 93, with some merged and others reorganised to better reflect modern cyber security practices and emerging threats.

By consolidating and reorganising controls, the update improves usability, allowing businesses to identify, apply, and manage security measures more effectively.

Updated security controls

ISO 27001:2022 introduces new controls that are aligned with the most recent advancements in cyber security.

These include:

• Threat intelligence to proactively identify and mitigate emerging risks
• Cloud security to address the challenges of cloud-based environments
• Data leakage prevention to protect sensitive information from unauthorised access
• Secure coding practices to strengthen application development security
• Physical security monitoring to detect and respond to potential breaches in physical infrastructure

New control categories

The updated framework includes four new control categories to help manage and evaluate security measures. These are people, organisational, technological, and physical controls.

• People controls focus on human factors such as training, awareness, and behaviour management
• Organisational controls cover policies, governance, and compliance frameworks
• Technological controls address tools, software, and systems designed to protect information and infrastructure
• Physical controls include measures to safeguard physical assets and facilities, such as access restrictions and surveillance systems

Enhanced documentation and reporting requirements

The new framework introduces new, more prominent requirements for documenting and reporting information security performance and incidents.

Organisations must now keep detailed records of their security policies, procedures, and risk assessments in order to demonstrate compliance and support continuous improvement.

Clear incident reporting protocols are also required, along with guidelines for logging, analysing, and reporting security incidents, to assist organisations in responding more effectively and preventing future occurrences.

Regular performance monitoring is now also required, with reports on key security metrics required, to help control the effectiveness of security systems and inform decision-making.

Clear audit trails are also now required to provide traceability and accountability for internal and external regulatory reviews.

Alignment with other ISO standards

The updated ISO 27001:2022 is aligned with ISO 27002:2022, a similar international standard that provides guidelines and best practices for information security controls.

The ISO 27001:2022 establishes a framework for managing information security risks, whereas ISO 27002:2022 provides detailed guidance on how to implement the controls required by ISO 27001.

By aligning the two standards, organisations can more effectively implement security measures that are relevant, up to date, and in line with modern cyber security threats.

The revised framework also improves compatibility with other related standards, including ISO 27701 (privacy information management) and ISO 27017 (cloud security).

This simplifies the process for organisations that manage multiple certifications, resulting in a more cohesive approach to information security, privacy, and cloud governance.

The risks of delaying the transition

Organisations that do not complete the ISO 27001 transition by the deadline will face significant risks. These include:

Loss of certification

As briefly mentioned earlier in the article, businesses who fail to transition to ISO 27001:2022 before the October 31st deadline will lose their ISO 27001 certification.

These businesses will therefore be required to undergo the entire certification process from the beginning.

This will not only involve significant financial costs, but also demand considerable time and resources, potentially resulting in compliance gaps, operational disruptions, and a loss of any competitive advantage.

Increased compliance costs

Delaying the transition to ISO 27001:2022 can lead to last-minute, rushed audits, putting more pressure on internal teams and increasing the risk of noncompliance.

Organisations may also be charged emergency consultancy fees to expedite the process, adding unexpected costs.

As well as this, the rushed transition can cause operational disruptions, diverting resources away from critical business functions and potentially jeopardising security and regulatory compliance.

Regulatory and contractual risks

Losing the ISO 27001 certification could result in noncompliance with industry regulations, potentially resulting in regulatory fines, reputational damage, and scrutiny from governing bodies.

Additionally, many business contracts, particularly in finance, healthcare, and technology, require ISO 27001 certification as a condition of partnership. Failure to maintain certification may result in contract losses, reduced market credibility, and diminished trust from clients and stakeholders.

Weakened security posture

Continuing to use an outdated security framework exposes organisations to emerging cyber threats that modern controls are designed to mitigate.

Without the enhanced safeguards outlined in ISO 27001:2022, businesses face a higher risk of data breaches, financial losses from cyber incidents, regulatory penalties, and reputational harm, which could erode customer trust and market positioning.

How Net-Defence can help

At Net-Defence, we specialise in guiding organisations through the ISO 27001 transition process, ensuring full compliance while minimising disruption to business operations. We can provide:

Gap analysis and readiness assessments

We will conduct a thorough assessment of your existing ISO 27001:2013 framework, carefully analysing your current policies, controls, and processes to identify necessary updates and areas for improvement and provide actionable recommendations.

Customised transition strategy

We develop a custom transition roadmap that is meticulously designed to align with your organisation’s unique structure, industry-specific requirements, and security goals.

Documentation and policy updates

We ensure that all business policies, procedures, and controls are thoroughly reviewed, updated, and optimised to meet the most recent ISO 27001:2022 compliance standards.

Implementation support

We provide expert advice to help you establish the security controls, frameworks, and processes required for the ISO 27001 transition.

Employee training and awareness

We provide specialised training that equips teams with the knowledge and practical skills required to understand, adopt, and effectively implement the new security requirements in their daily operations.

Audit preparation and support

We provide expert guidance throughout the ISO 27001 audit process, ensuring a smooth transition for your business and a successful certification renewal.

Obtaining ISO 27001 certification not only improves your organisation’s security posture, but it also demonstrates a commitment to data protection and continuous improvement in information security practices.

From initial planning to final certification, we provide comprehensive support to ensure your organisation meets ISO 27001:2022 requirements efficiently and confidently. We are committed to supporting organisations through this transition with expert guidance, strategic planning, and a streamlined approach to certification.