ISO 27001 in 2026: Why the Latest Controls Update Still Catches Experienced Teams Off Guard
It is January 2026. The October 2025 transition deadline for ISO 27001:2022 has passed. That version is now the only one accepted for new certifications and renewals. There is no brand-new 2026 edition or major controls overhaul. The "latest" changes people keep referring to are still the 2022 revision of Annex A plus the small 2024 Amendment 1 on climate action considerations.
Yet teams with long histories under the 2013 version are running into surveillance audit findings, delayed recertifications, or rework they did not expect. Why does this keep happening to people who should know better?
The main clauses (4 through 10) changed very little. The real shift happened in Annex A: 114 controls dropped to 93, reorganized into four themes (organizational, people, physical, technological), with 11 genuinely new controls added and others merged or refined. The new ones include threat intelligence (A.5.7), information security for cloud services (A.5.23), configuration management (A.8.9), data masking (A.8.11), and data leakage prevention (A.8.12).
Experienced teams often assume their existing setup already covers the intent of these controls. In 2013 audits, generic policies and annual reviews were frequently enough. In 2026, auditors expect to see active, measurable processes. They ask for evidence of daily threat intelligence ingestion and response, detailed cloud shared-responsibility assessments, automated configuration drift detection, and tested data masking where sensitive data flows. If your Statement of Applicability still uses old numbering or lacks clear justification for exclusions under the new structure, you get hit.
The 2024 Amendment 1 is another quiet trap. It modifies clauses 4.1 and 4.2 to require organizations to evaluate whether climate-related issues (extreme weather events, supply chain disruptions from environmental factors) are relevant to the ISMS context or the needs and expectations of interested parties. You must document the assessment, even if the conclusion is "not relevant." Many long-time certified teams dismiss this as redundant with business continuity planning and skip the explicit write-up. Auditors flag it as a missing input to risk assessment. It is usually a minor non-conformity, but it adds up when combined with other gaps.
These changes also interact with newer regulations. The 2022 controls map more cleanly to NIS2, DORA, GDPR, and similar frameworks because of the added focus on cloud security, threat intelligence, and data protection techniques. However, mapping is not the same as compliance. Teams discover that "we have a cloud control" does not satisfy specific DORA requirements for ICT third-party risk monitoring or NIS2 supply-chain obligations unless the processes are demonstrably operational and evidenced.
Here are the most frequent blind spots I see among experienced groups right now:
Auditors emphasize outcomes and metrics (time to detect incidents, patch compliance rates, access review completion percentages) over the existence of documents.
Threat intelligence is treated as an annual task instead of a continuous feed with documented action.
New controls like data masking and leakage prevention get a tool purchase but lack testing and effectiveness measurement.
Internal auditors have not fully internalized ISO 27002:2022 guidance and miss opportunities for improvement.
Climate relevance assessments are omitted or poorly justified.
If your ISMS was genuinely mature and risk-driven under 2013, the 2022 version should feel like an improvement: fewer controls overall, better alignment to current threats, and clearer implementation guidance in 27002. The surprise usually comes from treating transition as a paperwork exercise rather than a prompt to revisit risk assessments, update training, and strengthen evidence collection.
For teams still feeling the pain in 2026, practical next steps include running a targeted gap check against the full 2022 Annex A plus the climate amendment, prioritizing the 11 new controls in the risk treatment plan, refreshing internal audit competence, and tracking control performance metrics for management reviews.
The standard moved forward to reflect actual threats. Organizations that use the changes to strengthen operations are in good shape. Those that minimized them are still paying the price.