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ISO 27701:2025: what changed and what to do now

ISO/IEC 27701:2025, published on 14 October 2025, turns the privacy standard into a standalone management system: you no longer need an ISO/IEC 27001 ISMS to implement or certify it. It follows the harmonized structure of clauses 4 to 10 and has an Annex A with 78 reference controls in three tables: A.1 for PII controllers, A.2 for PII processors and A.3 for the security of personal data. Organizations certified to the 2019 edition must transition within the period set by accreditation bodies (for example, by 31 October 2028 in Canada's SCC rules).

2019 vs 2025 at a glance

TopicISO/IEC 27701:2019ISO/IEC 27701:2025
Type of standardExtension to ISO/IEC 27001 and 27002Standalone management system standard
PrerequisiteAn ISO/IEC 27001 ISMSNone (it can still be integrated with an ISMS)
StructureClauses mapped onto ISO/IEC 27001Harmonized structure, clauses 4 to 10
ControlsAnnex A (controllers) and Annex B (processors), plus extended ISO/IEC 27002 guidanceAnnex A with three tables: A.1 controllers, A.2 processors, A.3 security of PII (78 controls)
GuidanceSpread across clauses 6 to 8Annex B, with the same numbering as Annex A
MappingsISO/IEC 29100, GDPR, other standardsInformative annexes with mappings, including GDPR and a 2019-to-2025 correspondence

What it means for you

The Annex A tables in 2025

TableForMain topics
A.1PII controllersConditions for collection and processing (lawful basis, consent, DPIA, records), obligations to PII principals (notices, rights, automated decisions), privacy by design and by default, sharing, transfers and disclosures
A.2PII processorsContracts and instructions, obligations to customers, privacy by design for processing, transfers, subprocessors and disclosures
A.3Both rolesSecurity of personal data: policies, roles, access, cryptography, logging, incidents and breaches, backups, suppliers, secure development and more

Most organizations are both controller and processor (for example, for their own staff and for customer data), so they apply A.1, A.2 and A.3 and justify each inclusion or exclusion in the Statement of Applicability.

Transition steps for 2019-certified organizations

Get the free sample See the ISO 27701:2025 toolkit with GDPR and US annexes

Frequently asked questions

When was ISO/IEC 27701:2025 published?

On 14 October 2025. It replaces the 2019 edition.

Do I need ISO 27001 to get ISO 27701 certified?

Not with the 2025 edition. It is a standalone management system standard, although it integrates easily with ISO/IEC 27001.

How many controls does ISO 27701:2025 have?

Annex A lists 78 reference controls in three tables: A.1 for controllers, A.2 for processors and A.3 for the security of personal data. You justify which ones apply in your Statement of Applicability.

What is the transition deadline?

Accreditation bodies set it. For example, Canada's SCC requires certified clients to transition by 31 October 2028. Ask your certification body for yours.

Does ISO 27701 certification prove GDPR compliance?

No. It is strong evidence of a managed privacy program, but GDPR compliance depends on meeting each legal obligation.

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Updated: 2026-10-20