When it comes to building software, many organisations choose to look outside their own walls for talent. Whether it is a specialist agency, a freelance developer, or an offshore team, outsourcing can speed up delivery and lower costs. However, from a security perspective, it often feels like handing over the keys to your house and hoping the guest doesn’t leave the back door open. This is exactly why the transition from the ISO 27001:2013 standard to the 2022 update is so critical for modern businesses.
If you were familiar with the 2013 version, you might remember Control A.14.2.7 (Outsourced Development). In the 2022 revision, this has been refined and re-categorised as Annex A 8.30: Outsourced Development. While the core mission remains the same, protecting your data when someone else is writing the code, the 2022 version demands a much more proactive and structured approach.
Table of contents
The Structural Shift: From Domain 14 to Technological Controls
The first thing you will notice is where this control lives. In the 2013 version, it was part of a large, sometimes technical “Domain 14” regarding system acquisition and maintenance. In the 2022 version, the standard has been simplified into four themes: Organisational, People, Physical, and Technological.
Annex A 8.30 now sits within the Technological Controls. This shift isn’t just about moving folders around; it highlights that managing outsourced development is a technical safeguard that requires active supervision and validation. It’s no longer just an “administrative” task of signing a contract; it is a technical requirement to monitor the work itself.
What Exactly Has Changed in the Requirements?
The 2013 version of the standard was somewhat “light” on the specifics of how you should manage a third-party developer. It focused heavily on the fact that you should have an agreement. The 2022 update, however, reflects the reality of modern supply chain risks.
Under Annex A 8.30, the emphasis has moved from “having an agreement” to directing, monitoring, and reviewing. According to the insights from Hightable.io, this means you can no longer treat outsourcing as a “fire and forget” activity. You are now expected to treat external developers as an extension of your own internal team, holding them to the same rigorous security standards you apply to your own staff.
Key New Areas of Focus
When comparing the two versions, there are several areas where the 2022 standard expects more from you:
- Governance and Supervision: You must prove that you are actually supervising the development. This might include regular security meetings, reviewing sprint cycles for security features, or having a seat at the table during design reviews.
- The Contract is King: While the 2013 version mentioned agreements, 8.30 is much firmer. Your contracts must now explicitly define secure coding practices, vulnerability management requirements, and your “right to audit” their processes.
- Licensing and Intellectual Property: There is a stronger focus on ensuring you actually own the code produced and that the developer isn’t using “poison pill” open-source licences that could compromise your proprietary software.
- Testing and Acceptance: The 2022 standard expects you to perform your own security testing on delivered code. You shouldn’t just take the developer’s word that it is safe; you need to verify it via methods like static or dynamic analysis (SAST/DAST).
Why the Change? The “Trust but Verify” Mindset
The world has changed since 2013. We’ve seen high-profile supply chain attacks where a vulnerability in a small, outsourced component led to a massive data breach. The ISO committee recognised that many organisations were “outsourcing their risk” alongside their development, thinking that if a third party wrote the code, the third party was responsible for its security.
As Hightable.io points out, you can outsource the work, but you can never outsource the responsibility. Annex A 8.30 is designed to close that loophole, forcing organisations to take ownership of the security outcomes of their external partners.
How to Implement the New 8.30 Controls
If you are moving from the 2013 standard to the 2022 version, your transition plan should include the following steps:
- Review Your Supplier Contracts: Ensure they aren’t just generic templates. They need to include specific security clauses, such as mandatory adherence to OWASP guidelines or specific encryption standards.
- Establish a Monitoring Routine: Don’t wait until the end of the project to check for security. Build “security checkpoints” into your project management milestones.
- Perform Due Diligence: Before hiring a developer, vet their security culture. Do they have their own ISO 27001 certification? How do they handle their own internal security incidents?
- Define “Acceptance”: Create a formal checklist for when you receive code. If it doesn’t pass a vulnerability scan or meet your architecture requirements, it shouldn’t be accepted into your production environment.
Conclusion
The move from ISO 27001:2013 to 2022 represents a significant hardening of the rules around outsourced development. By introducing Annex A 8.30, the standard ensures that your security perimeter doesn’t end at your office wall, it extends to every line of code written on your behalf, no matter where in the world the developer is sitting. It is a transition from passive trust to active verification, and while it requires more oversight, it ultimately leads to a much more resilient organisation.