The Definitive Governance Requirement.
Clause 5.1 mandates that Top Management must demonstrate active leadership and commitment to the ISMS. It explicitly removes the ability to delegate total accountability to the IT department. If the Board is not driving the car, the car is not compliant.
The Mandate
The days of the CISO signing off in a basement are over. The standard places the ultimate responsibility for information security squarely on the shoulders of “Top Management” (C-Suite/Board).
The requirements are absolute:
- Alignment: The ISMS policy and objectives must align with the strategic direction of the business. You cannot have a security policy that contradicts your business model.
- Resources: Management must provide the budget, people, and infrastructure required (Clause 7.1).
- Communication: Management must communicate the importance of effective information security management.
- Support: Management must direct and support persons to contribute to the effectiveness of the ISMS.
The Implementation Strategy
Do not simply ask the CEO for a signature. You must build a Governance Structure.
- The Policy Signature: The Information Security Policy must be authorized by the highest level of management. This is the first artifact an auditor requests.
- The Management Review: Establish a cadence (quarterly or bi-annually) where the Board reviews the ISMS performance (Clause 9.3). Minutes from these meetings are your primary defense.
- Integration: Stop treating security as a bolt-on. Embed security requirements into business processes (e.g., procurement, HR onboarding, project management).
- Resource Allocation: Document the budget approval for security tools and training. A budget is evidence of commitment.
The Auditor’s Trap
[The Auditor’s View] The most common Major Non-Conformance here is “The Absentee Landlord.” During the audit, I will interview the CEO or Managing Director. I will ask them: “What are your top three information security objectives this year?” If they look at the CISO for the answer, the audit is over. They must own the narrative.
Required Evidence
An auditor looks for proof of active involvement, not just passive permission.
- Signed Information Security Policy: Dated and authorized.
- Job Descriptions: Showing security responsibilities assigned to top roles.
- Management Review Minutes: The “smoking gun” of leadership involvement.
- Budgetary Records: Proof of financial support for the ISMS.
- Internal Communications: Emails or Town Hall slides where leadership discusses security.
Strategic Acceleration
Executives do not have time to guess what “Commitment” looks like. You must script it for them.
The Hightable™ Toolkit includes the Management Review Agenda and Leadership Declaration templates. These documents put the correct words in the Board’s mouth, ensuring they demonstrate compliance without wasting their time.
The Next Move: Deploy the Leadership Framework