In the modern business landscape, very few companies operate in a vacuum. We rely on cloud providers, software vendors, and specialized consultants to keep the wheels turning. This interconnectedness is a superpower, but from a security perspective, it is also a significant vulnerability. ISO 27001 has always recognized this, but the 2022 update brings a much-needed modernization to how we manage these third-party risks under the new Annex A 5.19.
If you are transitioning from the 2013 standard, you might be wondering if Annex A 5.19 is just a new label for an old process. The answer is a bit of both. While the core mission remains the same, the scope and the “how” have shifted. Let’s look at what has changed and why it matters for your supply chain security.
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The Structural Shift: From Domain 15 to Theme 5
In the 2013 version of ISO 27001, supplier security lived in its own dedicated neighborhood: Domain A.15 (Supplier Relationships). It was broken down into several specific sub-controls, primarily starting with A.15.1.1 (Information security policy for supplier relationships).
In the 2022 update, the standard has been reorganized into four “themes.” Annex A 5.19, now titled “Information Security in Supplier Relationships,” is classified as an Organizational Control. This structural change is more than cosmetic; it signals that supplier management is no longer just a technical checkbox for the IT department. It is a fundamental governance process that requires cooperation between procurement, legal, and security teams.
What Exactly Moved to Annex A 5.19?
For those mapping their 2013 controls to the 2022 version, Annex A 5.19 is the direct successor to the old A.15.1.1. However, its reach has expanded. While A.15.1.1 was focused heavily on having a policy in place, the new Annex A 5.19 is a more comprehensive “preventive” control.
According to the experts at Hightable.io, the purpose of this update is to ensure that you maintain an agreed level of security across all supplier interactions. It serves as the foundation for the controls that follow it (like 5.20 for agreements and 5.21 for the ICT supply chain), acting as the “master process” for how you identify, assess, and manage those third-party risks.
The Move Toward a Risk-Based Lifecycle
The 2013 version was often criticized for being a bit static—you checked a supplier’s credentials when you hired them, and that was often the end of the story. The 2022 update for Annex A 5.19 pushes for a more dynamic, lifecycle-based approach.
The new requirements emphasise that you must define and implement processes to manage the risks associated with the use of a supplier’s products or services. As noted by Hightable.io, this means your “Supplier Register” needs to be more than just a list of names. It should be a living document that classifies suppliers by risk, not just by how much they cost, but by the sensitivity of the data they handle and the criticality of the service they provide.
Key Nuances in the 2022 Version
While much of the 2013 guidance on “policies” remains, Annex A 5.19 introduces several modern expectations that align with today’s digital reality:
- Handling Incidents: There is a clearer expectation that your supplier management process includes how to handle security incidents that happen at the supplier’s end.
- Access Management: The 2022 version places a heavier emphasis on documenting and controlling exactly what a supplier can “access, monitor, and use” within your environment.
- Supply Chain Continuity: While business continuity has its own home in the standard, Annex A 5.19 explicitly links supplier relationships to your availability and disaster recovery plans.
Practical Impact: Modernizing Your Supplier Policy
If you are transitioning to the 2022 version, your main task for Annex A 5.19 is to evolve your “Supplier Security Policy” into a “Supplier Management Process.” This isn’t just about what they should do, but how you ensure they are doing it.
For example, if a supplier handles personal data, they are a “data processor” under regulations like GDPR. Annex A 5.19 requires you to prove you have verified their security posture. Hightable.io highlights that auditors are now looking for the “link” between your risk assessment and your supplier contract, if a risk is identified, does the contract actually address it?
Why This Change Strengthens Your Security
The shift to Annex A 5.19 reflects the hard lessons learned from the “supply chain attacks” of recent years. We’ve seen that even the most secure organization can be compromised through a vulnerable third-party tool. By treating supplier relationships as an organizational control, ISO 27001:2022 forces us to look beyond our own firewalls.
Ultimately, the transition from the 2013 version is about maturity. It moves the focus from “Do we have a policy?” to “Are we actually managing the risk?” For those looking to bridge the gap without starting from scratch, utilizing the mapping tools and supplier registers provided by Hightable.io can help ensure your transition is both compliant and genuinely effective for your business.