The New "Big Three": How ISO 27701:2025 Completes the Modern Governance Playbook
ISO/IEC 27701 was finally released!
In the summer of 2010, the landscape of professional basketball was fundamentally altered. Three of the league’s top players—LeBron James, Dwyane Wade, and Chris Bosh—all franchise cornerstones and scoring leaders from the same 2003 draft class, decided to join forces on the Miami Heat.
This was not merely an accumulation of talent; it was the strategic assembly of a “superteam.” Each player brought a distinct, elite skill set: Wade, the established champion and explosive scorer; James, the versatile, do-it-all MVP; and Bosh, the adaptable big man who could stretch the floor. Together, they created a synergistic force that dominated the league, reaching the NBA Finals in all four of their seasons together and winning two championships. If it wasn’t for Dirk Nowitzki, this team could have been the most successful ever assembled.
Today, in the world of governance, risk, and compliance, a similar “Big Three” has emerged. The convergence of data-driven business models, the rapid rise of artificial intelligence, and a complex web of global regulations has created the need for a new kind of strategic alignment.
Organizations can no longer treat information security, AI governance, and data privacy as separate disciplines. To build and maintain trust in the modern digital economy, they need an integrated playbook. This playbook is defined by a trio of powerful ISO management system standards.
The ISO “Big Three”
ISO/IEC 27001: This is the established champion, the bedrock of the team. As the international standard for an Information Security Management System (ISMS), ISO 27001 provides a comprehensive, risk-based framework for protecting the confidentiality, integrity, and availability of all organizational information. It is not just about IT security; it encompasses people, processes, and technology to manage information risks effectively.
ISO/IEC 42001: This is the versatile, forward-looking standard that adapts to the new reality. ISO 42001 specifies the requirements for an Artificial Intelligence Management System (AIMS), addressing the unique risks and opportunities presented by AI. It provides a structured approach to managing the entire AI lifecycle, from design and development to deployment and decommissioning. The standard focuses on promoting responsible AI use by tackling challenges like ethical considerations, transparency, accountability, and bias mitigation, ensuring that innovation happens within a controlled and trustworthy framework.
ISO/IEC 27701: This is the standard that completes the team. ISO 27701 specifies the requirements for a Privacy Information Management System (PIMS). It takes the robust security foundation of ISO 27001 and applies a specific, rigorous focus on the protection of personally identifiable information (PII). A PIMS provides the blueprint for complying with a growing number of global privacy regulations, most notably the EU’s General Data Protection Regulation (GDPR).
The assembly of these three standards marks a significant evolution in enterprise risk management. It signals a move away from siloed compliance activities and toward an integrated governance model. The business environment is now defined by the interplay of data operations (requiring security), AI tools (requiring AI governance), and privacy obligations (requiring privacy management).
These are not separate challenges; they are interconnected facets of a single, overarching question: how can an organization use data and technology responsibly to create value?
This trio of standards provides the market with a holistic, internationally recognized, and auditable “Trust Framework.” Companies are no longer just selling a product or service; they are selling trust. The ISO “Big Three” provides the definitive blueprint for demonstrating it. This shift will inevitably drive a convergence of roles within organizations, requiring Chief Information Security Officers, Chief Privacy Officers, and emerging Chief AI Officers to work from a common playbook.
Why ISO 27701:2019 Was Sidelined
For any championship team to function, its key players must be on the court and in sync. For the past few years, a critical member of the governance “Big Three” was effectively stuck on the bench due to a technicality. The 2019 version of ISO 27701, while conceptually powerful, was hampered by a structural dependency that rendered it incompatible with the latest security best practices.
The original ISO 27701:2019 was designed not as a standalone standard, but as a privacy extension to ISO 27001. Its entire structure was built upon the foundation of an existing Information Security Management System (ISMS). The PIMS it described borrowed its core security controls directly from the Annex A of the then-current version of the security standard, ISO 27001:2013. This tight coupling was its greatest strength and, ultimately, its critical weakness.
In October 2022, the foundational standard, ISO/IEC 27001, received a major update to its 2022 version. This was not a minor revision. The update completely restructured the heart of the standard: the Annex A security controls. The old framework of 14 domains and 114 controls was replaced with a more modern structure of 4 themes and 93 controls. More importantly, 11 new controls were introduced to address contemporary threats such as insecure cloud configurations, the need for proactive threat intelligence, and the prevention of data leakage.
This created a technical impasse. ISO 27701:2019 was hardwired to the old, outdated 2013 control set. Its clauses directly referenced control numbers and structures that no longer existed in the new ISO 27001:2022 standard. As a result, organizations that proactively transitioned their ISMS to the new 2022 security standard found themselves in a compliance paradox. While they had a state-of-the-art security program, it was technically impossible for them to obtain an accredited ISO 27701 certification. The two standards were simply out of sync, making a unified audit against both impossible. This wasn’t a theoretical problem; it created real business friction for companies needing to demonstrate both leading-edge security and privacy compliance in contracts and tenders.
The delay in resolving this issue was further complicated by a behind-the-scenes dependency. The update to ISO 27701 could not be released until its own supporting standard, ISO/IEC 27706, was also overhauled. ISO 27706 is the standard that defines the requirements for the bodies that audit and certify PIMS. In essence, the rules of the game (27701) could not be updated until the rulebook for the referees (27706) was rewritten to match.
This multi-year standards logjam left the industry in a state of compliance limbo, highlighting the inherent fragility of a tightly coupled extension model where standards evolve at different paces. The challenges born from this experience have directly informed the more resilient, independent structure of the new 2025 revision.
A Deep Dive into the ISO 27701:2025 Update
The release of ISO/IEC 27701:2025 resolves the technical misalignment and introduces significant structural improvements that make the standard more flexible, accessible, and relevant to modern business challenges. It is now fully aligned with ISO 27001:2022 and brings a new level of maturity to privacy management.
Merged Annexes for Controllers and Processors
The 2019 version of the standard separated its privacy-specific controls into two different annexes: one for PII Controllers and another for PII Processors. The 2025 revision merges these into a single, consolidated Annex A, organized into Table A.1 (for PII Controllers) and Table A.2 (for PII Processors).
This change reflects the complex reality of modern data processing. Many organizations, particularly in the cloud and SaaS industries, operate as both a controller and a processor. They act as a controller for their own employee and direct customer data, while simultaneously acting as a processor for the data their clients upload and manage using their service. The previous structure could lead to duplicative documentation and a more cumbersome audit process. The new, consolidated annex simplifies implementation for these dual-role organizations, allowing for a more streamlined and logical approach to defining and applying privacy controls. Across these two tables, a total of 49 privacy-specific controls remain.
Table A.3 and the Standalone PIMS
Perhaps the most impactful change in the 2025 version is the introduction of a new Table A.3 in Annex A. This table contains a set of 29 parsed security controls specifically for organizations that do not have an established ISMS certified to ISO 27001.
This is a fundamental shift. It transforms ISO 27701 from a simple “add-on” into a certifiable, standalone management system. Previously, an organization had to endure the significant time and resource investment of a full ISO 27001 implementation before it could even begin the ISO 27701 certification process. Now, an organization whose primary risks and market drivers are centered on privacy can pursue a PIMS certification directly. This makes an internationally recognized privacy certification far more accessible to a wider range of businesses, including startups and small-to-medium-sized enterprises that may have been deterred by the cost and complexity of the prerequisite. This change will likely reshape the privacy certification landscape, creating a new, more attainable entry point and increasing the competitive expectation for all companies handling personal data to seek formal certification.
Considering Climate Change in Your Privacy Program
In line with the 2021 ISO London Declaration, which commits to incorporating climate science into all international standards, the new ISO 27701 includes a requirement to consider climate change. This is not an abstract environmental pledge; it is a concrete risk management requirement embedded into the core of the management system.
The amendment adds new text to two key clauses:
Clause 4.1 (Understanding the organization and its context): “The organization shall determine whether climate change is a relevant issue.”
Clause 4.2 (Understanding the needs and expectations of interested parties): A new note clarifies that “Relevant interested parties can have requirements related to climate change.”
This forces organizations to analyze how climate change could impact their ability to protect PII.
Consistency is Key: What Stays the Same
Despite these significant updates, the core philosophy of the standard remains intact. The risk-based approach is still central. Organizations must still use a Statement of Applicability (SoA) to document which controls from Annex A are implemented and to provide a justification for any that are excluded based on the organization’s role as a PII controller or processor [User Query]. This ensures that the PIMS remains tailored to the specific privacy risks and context of each organization.
ISO 27701 and the GDPR Landscape
One of the most powerful drivers for adopting ISO 27701 is its close alignment with the requirements of the GDPR. However, it is crucial to understand the distinction between a management system certification and a formal, legal certification under the GDPR itself. Confusing the two can lead to significant misinterpretations of an organization’s compliance status.
ISO 27701 serves as an excellent operational framework to help an organization meet its GDPR obligations. The standard’s annexes provide a direct mapping of its privacy controls to the specific articles of the GDPR, offering a clear and practical roadmap for implementation. Achieving ISO 27701 certification is a powerful way to demonstrate adherence to the GDPR’s core principle of “accountability,” which requires organizations to not only comply with the regulation but also be able to prove it.
This, however, is not the same as an official GDPR certification as envisioned under Article 42 of the regulation. Article 42 outlines a mechanism for creating approved “data protection certification mechanisms, seals and marks”. An Article 42 certification would be issued by an accredited body based on criteria formally approved by a country’s national Data Protection Authority (DPA). Such a certification would attest that a specific data processing operation—for example, a particular software product or service—conforms to the GDPR’s legal requirements.
An ISO 27701 certification is different in nature and scope. It is an attestation from an accredited certification body that the organization has successfully implemented and maintains a management system to systematically identify, assess, and treat privacy risks. It is a globally recognized best-practice standard for process maturity, not a legal instrument created under the authority of the GDPR.
The slow and complex process of establishing official Article 42 certification schemes has meant that very few have been approved across Europe since the GDPR was enacted. This regulatory vacuum has inadvertently elevated the market importance of ISO 27701. In the absence of official GDPR “seals,” businesses needed a reliable and internationally understood tool to demonstrate privacy diligence in contracts, RFPs, and vendor assessments. ISO 27701 has filled that role, becoming the de facto global standard and the primary mechanism for organizations to provide assurance about their privacy governance.
Your Transition and Next Steps
The new ISO/IEC 27701:2025 standard is available for implementation immediately. For organizations looking to adopt it or transition from the previous version, a clear game plan is essential.
The Transition Clock
For organizations already certified to ISO 27701:2019, a formal transition period is now in effect. Typically, ISO allows up to 36 months for such transitions. However, the definitive deadline will be established by the International Accreditation Forum (IAF) in an official Mandatory Document (MD). Given that the supporting audit standard, ISO 27706, was published in parallel with the main standard, this transition period may be shorter than the typical three years. Regardless of the final date, all certifications to the 2019 version will expire or be withdrawn at the end of this period, making a timely transition mandatory to maintain certification.
Actionable Advice for Your Organization
The right approach depends on your organization’s current certification status.
If You Are Currently Certified to ISO 27701:2019: Your immediate priority is to plan the transition. Begin by conducting a thorough gap analysis to compare your existing PIMS against the new 2025 requirements. Key areas of focus should be the restructured Annex A controls, the integration of the new climate change considerations into your context and risk assessment processes, and any necessary updates to your Statement of Applicability. Contact your certification body to schedule a transition audit, which can often be combined with your next planned surveillance or recertification audit to improve efficiency.
If You Are Certified to ISO 27001:2022 and Want to Add Privacy: You are in an ideal position. The new ISO 27701:2025 is specifically designed to align seamlessly with your existing ISMS. The technical conflicts of the past have been eliminated. You can now extend your current management system to incorporate the PIMS requirements, leveraging your established risk assessment methodologies and security controls as a strong foundation for your privacy program.
If You Are New to ISO Privacy Standards: You now face a strategic choice that did not exist before. You can pursue the new standalone PIMS certification by implementing the core security controls outlined in Table A.3. This is a more direct and potentially less resource-intensive path to a recognized privacy certification. Alternatively, you can pursue the “gold standard” approach: implementing a full ISMS according to ISO 27001:2022 first, and then integrating the PIMS via ISO 27701:2025. The best path depends on your organization’s specific risk profile, resources, market demands, and long-term strategic goals.
Ultimately, the transition to ISO 27701:2025 should be viewed as more than a simple compliance deadline. It presents a strategic opportunity for organizations to re-evaluate and mature their entire privacy program. The mandatory review forced by the transition is a catalyst to ask deeper questions. Is our privacy risk assessment process robust enough to handle emerging threats from AI? Have we adequately considered the resilience of our PII processing against plausible climate-related disruptions? Companies that treat this transition as a strategic review will emerge with a stronger, more resilient, and more valuable privacy program. Those that view it as a purely administrative task may achieve certification but will miss the chance to genuinely improve their posture, leaving them more exposed to the risks of tomorrow.
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