ISO/IEC 27701:2025: What You Need to Know

In October 2025, the International Organization for Standardization (ISO) has officially released the ISO/IEC 27701:2025, the updated international standard for Privacy Information Management Systems (PIMS). This new edition marks a significant evolution in the way organizations manage personal data protection and privacy governance.

In this article, we provide a clear breakdown of the key changes, outline what the updates mean for both organizations and individual professionals, and offer practical guidance to help you prepare for a smooth and effective transition.

A New Stand-Alone Standard for Privacy Management

Unlike the 2019 version, which functioned as an extension of ISO/IEC 27001 and ISO/IEC 27002, the 2025 edition stands on its own. Organizations can now implement and certify a PIMS independently, without requiring an established Information Security Management System (ISMS).

This update opens the door for a wider range of organizations — including those without an ISMS — to adopt a globally recognized privacy framework that focuses directly on personal data protection, privacy risks, and compliance requirements.

ISO/IEC 27701:2025 structure is aligned with standard management system frameworks such as ISO/IEC 27001, ISO/IEC 42001, ISO 9001, and ISO 22301. This alignment simplifies integration in multi-standard environments and enhances coherence for organizations managing multiple certifications.

Key Changes between ISO/IEC 27701:2019 and ISO/IEC 27701:2025

Clause Structure Updates

Updated Clause-by-Clause Requirements

Clauses 4–10 have been refined to ensure better focus and practicality:

• Clause 4 (Context of the organization): The 2025 edition expands the scope by requiring organizations to consider internal and external factors, including legal, regulatory, governance, and climate-related obligations, when defining the PIMS context. It also clarifies expectations for identifying relevant interested parties and addressing their requirements. A key change is that the scope determination now focuses on defining the PIMS scope rather than the ISMS scope.
• Clause 5 (Leadership): Different from 2019, where only the ISMS leadership requirements applied, this clause defines leadership accountability, requiring top management to align the privacy policy and objectives with the organization’s direction, integrate PIMS into business processes, allocate resources, and promote continual improvement. It clarifies establishing an appropriate privacy policy, setting objectives, meeting requirements, and ensuring documentation and communication. Leadership must also assign and communicate roles, maintain conformance, and report PIMS performance at the highest level, emphasizing direct oversight of privacy management.
• Clause 6 (Planning):  It explicitly defines PIMS planning and risk management, removing reliance on ISO/IEC 27001. Organizations must consider context and interested parties, conduct structured privacy risk assessments, and document treatment plans for privacy and security risks. Objectives are now privacy-specific and measurable. A new clause, 6.3 “Planning of Changes,” has also been introduced to formalize how PIMS modifications should be managed
• Clause 7 (Support and operation): This clause replaces references to ISO/IEC 27001 with standalone requirements. It directs organizations to allocate resources, ensure personnel competence and awareness, and define clear communication regarding the PIMS. Documentation requirements are explicit, covering creation, review, approval, version control, storage, retention, and disposition. These updates enhance clarity, accountability, and operational effectiveness in managing the PIMS.
• Clause 8 (Operational guidance): It consolidates requirements for planning, assessing, and treating privacy risks within a single operational framework. The clause clarifies the need to plan, implement, and control PIMS processes, manage changes, and oversee outsourced services with documented evidence. It replaces “information security risk assessment” and “risk treatment” with privacy-specific requirements, emphasizing documented risk evaluations and the implementation of effective mitigation measures for identified privacy risks.
• Clause 9 (Performance evaluation): The 2025 edition replaces references to ISO/IEC 27001 with explicit requirements for monitoring, measurement, and evaluation of PIMS performance, including maintaining documented evidence of effectiveness. It mandates internal audits at planned intervals to assess conformity, implementation, and ongoing maintenance. Top management is also required to review the PIMS periodically to ensure its continued suitability, adequacy, and effectiveness.
• Clause 10 (Improvement): The clause now requires organizations to improve the suitability, adequacy, and effectiveness of the PIMS, rather than the ISMS. The 2025 version also provides a detailed process for managing nonconformities and implementing corrective actions.

Expanded Annexes and Mappings

The annexes in ISO/IEC 27701:2025 have been reorganized and expanded for clarity. The PIMS reference control objectives and controls for PII controllers and PII processors, along with their specific implementation guidance, are now covered in Annex A and Annex B of the standard.

The mapping to ISO/IEC 29100 continues to serve the same purpose as in the 2019 version, although the ISO/IEC 27701 controls have been updated. The same applies to Annex E, which includes the mappings to ISO/IEC 27018 and ISO/IEC 29151. The GDPR mapping in Annex D, in particular, has been revised to better illustrate how ISO/IEC 27701:2025 can serve as a certification framework for demonstrating compliance with global privacy laws. To help identify the key changes in privacy and information security controls, ISO/IEC 27701:2025 now includes Annex F, which provides a correspondence with ISO/IEC 27701:2019.

Changes to Annexes

The ISO/IEC 27701 annexes have been renamed and renumbered. Annex A is consolidated into one, where it was previously two separate annexes for PII processors and PII controllers. The revised Annex A now includes security controls for both PII controllers and PII processors, many of which align with information security controls found in ISO/IEC 27001 and ISO/IEC 27002.

Annex B contains fully rewritten and expanded implementation guidance replacing the 2019 guidance that was split between clauses 7 and 8. It provides practical detail for applying Annex A controls.

All other annexes remain unchanged, with the exception of Annex F. Annex F no longer offers guidance on implementing ISO/IEC 27701 in relation to ISO/IEC 27001 and ISO/IEC 27002; it now provides a mapping of the standard to its previous version.

What This Means for Organizations

The 2025 edition allows organizations to implement a PIMS independently, without requiring an existing ISMS. This shift increases flexibility and accessibility for organizations of all sizes and sectors. Key benefits include:

• Stronger focus on privacy, rather than technical ISMS integration.
• Simplified alignment with other management system standards.
• Enhanced clarity on legal requirements and stakeholder responsibilities.
• Updated guidance reflecting modern technologies, including cloud computing and AI.

Steps for a Smooth Transition

1. Conduct a Gap Analysis: Compare current PIMS practices against the 2025 clauses and annexes.
2. Update Documentation and Processes: Revise policies, procedures, and controls to align with the new structure.
3. Plan the migration timeline: Set clear internal milestones and align them with certification timelines.
4. Integrate Systems: If applicable, align with ISO/IEC 27001:2022 or other management systems.
5. Communicate & Educate Teams: Train privacy officers, IT, and compliance teams on updated terminology and requirements.
6. Continuous Improvement: Implement ongoing monitoring to ensure compliance and responsiveness to evolving privacy regulations.

The release of this standard it resets how organizations approach privacy governance. The deadline for transitioning to the new 2025 version of ISO/IEC 27701 standard is October 2028. Official transition rules from accreditation bodies are expected to be published soon.

Opportunities for Individuals: Advance Your Expertise

The transition to ISO/IEC 27701:2025 brings exciting opportunities for professionals looking to upskill or specialize in privacy management. Individuals can benefit from:

• Enhanced career prospects in privacy, data protection, compliance, and governance.
• Up-to-date knowledge of the latest PIMS requirements and implementation methods.
• Certification pathways that validate skills in privacy operations, auditing, and risk management.
• Training designed for both beginners and experienced professionals seeking deeper technical mastery.

Whether you are a privacy officer, IT professional, auditor, consultant, or aspiring data protection specialist, upgrading your skills through ISO/IEC 27701:2025 training helps you stay ahead in a rapidly evolving field.

The transition from ISO/IEC 27701:2019 to 2025 is more than a compliance update—it reflects a shift toward an independent, privacy-focused management system. By understanding these changes and adopting a structured transition approach, organizations can strengthen their privacy practices, enhance stakeholder trust, and remain compliant in a dynamic regulatory landscape.

Prepare for the Transition with PECB Training

Start your transition journey today with the ISO/IEC 27701:2025 Transition training course. The course includes an introduction to ISO/IEC 27701:2025 and its evolution from ISO/IEC 27701:2019, along with a clause-by-clause comparison and guidance on transition implementation.

If you are interested to take the training course please check here the planned training courses here contact us at support@pecb.com