Inside a Statement of Applicability (SoA): ISO 27001, 27701 & 42001 Explained

The Statement of Applicability (SoA) is the beating heart of your management system — whether ISO 27001 (security), ISO 27701 (privacy), or ISO 42001 (AI governance). It connects risks to controls and evidence, proving your program is intentional and effective.

ISO 27001 ISO 27701 ISO 42001 Risk linkage Audit-ready
Statement of Applicability linking risks, controls and evidence

What is the Statement of Applicability?

The SoA is the central document in ISO 27001, ISO 27701, and ISO 42001. It lists every relevant control from the respective Annex A, declares whether it is applied, excluded, or substituted, and justifies the decision with risk evidence.

Links Risk to Controls

Shows how each selected control addresses identified risks — ensuring your program is intentional, not arbitrary.

Defines Implementation

Documents where each control lives — in policy, process, technology, or people — with clear ownership.

Enables Auditability

Provides the evidence path and review cadence for every control — auditors start here.

Why the SoA Matters to Your Certification

A well-built SoA gives auditors confidence in your control design and maturity — and gives your team clarity on what’s required.

Transparency for Auditors

A current SoA shows your controls are deliberate and tied to real risks — building trust fast.

Clarity for Management

Summarises what’s in scope, what’s excluded, and the residual risk rationale — easy for executives to understand.

Efficiency for Teams

Prevents duplicated effort and streamlines evidence collection — saving weeks during audits.

What Auditors Look For

Auditors start with the SoA — it’s the index for your entire management system.

Traceability

Each selected/excluded control links back to the risk register.

Implementation Detail

Where and how the control operates — policy, process, technology, or people.

Evidence Pointers

Screenshots, exports, approvals, and review logs — clear and current.

Designing a Maintainable SoA

The best SoAs live inside your existing tools — a SharePoint list or Excel-in-SharePoint with versioning beats a static Word file. It keeps ownership clear and evidence current.

Scope & Risk

State scope, context, and risk methodology — keep it concise but specific.

Selection Rationale

Explain inclusions, exclusions, and any compensating controls.

Evidence Map

Reference folders and monthly snapshots — auditors can verify status instantly.

Sample Statement of Applicability (SoA) Table

Here’s a realistic example table (ISO 27001, 27701 & 42001 integrated). Auditors love this format — traceable, current, and evidence-linked.

Control ID Title Framework Risk Link / Rationale Status Owner Evidence Location Review Cadence
A.5.1 Information Security Policies ISO 27001 Risk of inconsistent security practices Implemented CISO /Evidence/Policies/InfoSec-Policy-v2.pdf Annual
A.8.2.1 Classification of Information ISO 27001 Risk of data leakage Implemented Data Owner /Evidence/Classification/Labels-Purview-Export.csv Quarterly
A.7.2.1 Data Subject Rights Handling ISO 27701 Risk of non-compliance with privacy rights Implemented Privacy Officer /Evidence/27701/DSR-Requests-Log.xlsx Monthly
A.5.1 (42001) AI Governance Policy ISO 42001 Risk of unethical AI use Implemented AI Governance Lead /Evidence/42001/AI-Policy-v1.pdf Annual
A.8.28 Secure Development ISO 27001 Risk of vulnerabilities in code Excluded N/A Compensating control: 3rd-party pen testing N/A
Download Free SoA Template (Excel)

Pre-filled with the example above — customize for your risks.

How the SoA Drives Your Compliance

The Statement of Applicability is the bridge between your risks and your controls — ensuring everything is intentional, auditable, and defensible.

Risks Identified

Start with your risk register — every control decision ties back here.

Controls Decided

The SoA documents what applies, what’s excluded, and why — with clear rationale.

Evidence Linked

Direct pointers to screenshots, logs, exports — auditors verify in seconds.

How the SoA Works Across ISO 27001, 27701 & 42001

The beauty of a unified SoA is that one table can cover multiple standards — reducing duplication and creating a single source of truth.

ISO 27001 (Security)

Core focus: protect information assets from threats — Annex A 93 controls.

ISO 27701 (Privacy)

Extends ISO 27001 with privacy controls (Annex A/B) — ROPA, DPIA, rights handling.

ISO 42001 (AI Governance)

Adds responsible AI controls — model inventory, risk assessment, oversight, monitoring.

Use one SoA — map overlapping controls (e.g. access control appears in all three) — and maintain a single evidence register. This saves time, reduces audit fatigue, and proves to stakeholders you have a cohesive program.

Statement of Applicability FAQs

Is the SoA mandatory?

Yes — it’s a core requirement of ISO 27001 Clause 6.1.3 and Annex A (also applies to ISO 27701 & ISO 42001).

How often should it be reviewed?

At least annually, or whenever scope, risk, or controls change.

Can we reuse it for other frameworks?

Yes — map controls to ISO 27701, ISO 42001, NIST CSF or SOC 2 to reduce duplicate effort.

Ready to Simplify Your SoA?

Book a free 30-minute call — we’ll show you how to build a maintainable SoA that links risks, controls and evidence across ISO 27001, 27701 and 42001.

Most teams build a strong SoA foundation in under 4 weeks.

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