If you have been working with information security standards for a while, you will know that the transition from ISO 27001:2013 to the ISO 27001:2022 update brought about some significant “housekeeping.” While the core requirements of the management system stayed largely the same, the Annex A controls underwent a massive facelift. One of the most important technical shifts involves how we handle different software environments.
Today, we’re looking specifically at Annex A 8.31, titled “Separation of development, test and production environments.” If you are wondering what changed from the 2013 version, you’re in the right place.
Table of contents
From Control 12.1.4 to Control 8.31: The Evolution
In the older ISO 27001:2013 standard, this concept lived under Control 12.1.4. It was tucked away in the “Operations Security” section. In the 2022 update, it has been reclassified as a “Technological Control” and renumbered to 8.31.
The core objective remains the same: you don’t want your developers accidentally breaking live systems, and you definitely don’t want hackers using a less-secure testing environment as a backdoor into your production data. However, the 2022 version is more aligned with modern DevOps, cloud computing, and automated deployment pipelines.
The Shift Toward Risk-Based Separation
The 2013 version was quite prescriptive but felt a bit dated for the era of “Infrastructure as Code.” The 2022 update, Annex A 8.31, focuses more on the segregation of duties and the protection of production data. According to experts at Hightable.io, the primary goal is to ensure that development and testing activities do not interfere with production activities or compromise the security of live information.
The new version acknowledges that “separation” doesn’t always mean physically different servers in a cupboard. It refers to logical separation, especially in cloud-native environments where virtualization and containerization are the norms.
Key Changes in Requirements
When comparing the two versions, there are a few specific nuances that have been sharpened in the 2022 iteration:
- Access Control Rigour: There is a heavier emphasis on ensuring that developers do not have access to production data unless it is absolutely necessary and strictly monitored.
- Data Protection: The 2022 version is much clearer about the use of “real” data. It strongly discourages using sensitive production data in testing environments. If you must use it, you need to apply equivalent security controls or use masking/anonymisation.
- Change Management Integration: Control 8.31 is now more tightly coupled with the rules for configuration management and change control. High-level guidance from Hightable.io suggests that the transition to 2022 is the perfect time to automate these environment gates to reduce human error.
Why Does This Matter for Your Audit?
Under the 2013 standard, auditors often looked for “silos.” Under ISO 27001:2022, they are looking for “governance.” They want to see that you have a documented policy for environment separation and that you can prove how you prevent unauthorised changes from jumping from a developer’s laptop straight into the live environment.
The 2022 version also introduces “Attributes” for each control. Annex A 8.31 is tagged as a “Preventative” control. This means your documentation needs to show how your setup prevents incidents before they happen, rather than just how you react to them.
How to Comply with Annex A 8.31
To meet the updated 2022 requirements, you should focus on three main pillars:
- Logical Isolation: Use separate cloud accounts, VPCs, or containers to ensure that a breach in “Dev” cannot move laterally to “Prod.”
- Identity Management: Implement the Principle of Least Privilege. Ensure that credentials used for development are distinct from those used for production.
- Deployment Pipelines: Use automated CI/CD tools that act as the only “bridge” between environments, ensuring that code is tested and scanned before it ever touches production.
The move to ISO 27001:2022 is more than just a numbering change; it’s a chance to modernise your security posture. By focusing on the refined requirements of Annex A 8.31, you can ensure your development lifecycle is both fast and secure.