ISO 27001:2022 isn’t a minor update — it’s a structural overhaul. The control set went from 114 controls in 14 domains to 93 controls in 4 themes. 11 new controls were added. And for GCC organizations that use ISO 27001 as their compliance backbone, the transition impacts everything from risk assessments to evidence collection.
The clock is ticking. Certificates issued against the 2013 version are expiring, and certification bodies are transitioning audits. If you haven’t started, you’re already behind.
What Actually Changed
The New Structure
| Theme | Controls | Scope |
|---|---|---|
| Organizational (5.x) | 37 | Policies, roles, asset management, supplier security |
| People (6.x) | 8 | Screening, training, responsibilities, remote working |
| Physical (7.x) | 14 | Perimeters, entry, offices, equipment, monitoring |
| Technological (8.x) | 34 | Endpoints, access, authentication, encryption, development |
The 11 New Controls
These additions reflect the evolving threat landscape and are particularly relevant for GCC organizations:
| Control | Name | Why It Matters for GCC |
|---|---|---|
| A.5.7 | Threat intelligence | GCC is a high-value target; threat intel is essential |
| A.5.23 | Cloud services security | Rapid cloud adoption + data residency concerns |
| A.5.30 | ICT readiness for business continuity | Aligns with UAE IA and NCA ECC resilience requirements |
| A.7.4 | Physical security monitoring | CCTV and physical surveillance — already common in GCC |
| A.8.9 | Configuration management | Baseline hardening — critical for reducing attack surface |
| A.8.10 | Information deletion | Data protection regulation alignment (PDPL, DIFC) |
| A.8.11 | Data masking | PII protection for financial and healthcare sectors |
| A.8.12 | Data leakage prevention | DLP is now explicitly required, not just recommended |
| A.8.16 | Monitoring activities | SOC/SIEM operations — aligns with continuous monitoring mandates |
| A.8.23 | Web filtering | Already enforced in many GCC environments |
| A.8.28 | Secure coding | AppSec maturity improvement for regional tech firms |
The Transition Process
Phase 1: Gap Analysis (2-4 Weeks)
Map your current 2013 Statement of Applicability (SoA) to the 2022 structure:
- Which of your existing controls map to which new control numbers?
- Which of the 11 new controls do you already partially address?
- Where are the genuine gaps?
💡 The Good News
Most organizations already implement 7-8 of the 11 “new” controls informally. Threat intelligence, monitoring, DLP, web filtering — these are common capabilities. The gap is usually documentation and formalization, not implementation.
Phase 2: Update Documentation (4-8 Weeks)
The documentation effort is significant but manageable:
- Statement of Applicability (SoA) — Complete rewrite to the new 93-control structure
- Risk treatment plan — Update to reference new control numbers
- Policies and procedures — Review and update references, add coverage for new controls
- ISMS manual — Update to reflect Annex SL harmonized structure changes
Phase 3: Implement New Controls (4-12 Weeks)
For the controls that require genuine new capability (not just documentation):
- A.5.7 Threat intelligence — If you don’t have a threat intel program, start with OSINT feeds, sector-specific IOCs, and integration with your SIEM
- A.5.23 Cloud services — Document your cloud security approach, shared responsibility model, and cloud-specific controls
- A.8.12 DLP — If you lack DLP tooling, implement at least email DLP and endpoint DLP for classified data
Phase 4: Transition Audit (Aligned with Audit Cycle)
Coordinate with your certification body. The transition audit can be combined with your regular surveillance or recertification audit to minimize disruption and cost.
ISO 27001:2022 + GCC Framework Alignment
The 2022 update actually improves alignment with GCC frameworks. The new controls (cloud security, threat intelligence, DLP, monitoring) are already required by UAE IA, NCA ECC, and CBUAE. This means:
- ISO 27001:2022 compliance gets you closer to GCC framework compliance than the 2013 version
- Cross-mapping between ISO and GCC frameworks becomes cleaner
- Evidence collected for ISO can be reused more directly for regional frameworks
Common Transition Mistakes
Avoid These
- Just renumbering controls — The 2022 structure isn’t a simple renumbering. Controls were merged, split, and reorganized. Don’t just search-and-replace control IDs.
- Ignoring attribute tagging — 2022 introduces control attributes (#preventive, #detective, #corrective, etc.). These are valuable for demonstrating control coverage and should be used.
- Rushing the SoA — The SoA is your auditor’s primary reference. A poor SoA creates problems throughout the audit.
- Not updating risk assessment — The new controls may introduce new risk scenarios. Your risk assessment needs to reflect the updated control set.
- Treating it as a one-time project — Transition is an opportunity to improve your ISMS, not just update paperwork.
The Compliance Platform Advantage
Organizations managing the transition manually face a documentation nightmare: updating SoAs, remapping risk treatments, revising evidence collection. A compliance platform with pre-built 2022 control libraries, automated cross-mapping, and evidence management transforms this from a 6-month project into a 6-week exercise.
The Bottom Line
ISO 27001:2022 is a better standard. The new controls reflect real-world threats. The restructured Annex A is more logical. And for GCC organizations, the improved alignment with regional frameworks reduces duplicate effort.
Don’t treat the transition as a burden — treat it as an upgrade. Your security program will be stronger for it.
Complyan provides complete ISO 27001:2022 transition support: pre-built control libraries, automated 2013→2022 mapping, SoA generation, and cross-mapping to GCC frameworks. Transition confidently with structured workflows and evidence management. Start your transition →