What is Management Review in ISO 27001?
Overview
Management Review is a mandatory evaluation conducted by top management to assess the continuing suitability, adequacy, and effectiveness of your ISMS. Required by ISO 27001:2022 Clause 9.3, it ensures leadership maintains oversight and drives strategic improvements to information security.
This is not a working-level meeting—it's a formal review by executives and decision-makers who can allocate resources and make strategic decisions about your ISMS.
Management Review in Practice
ISO 27001:2022 requires top management to review the ISMS at planned intervals (typically annually or semi-annually) to ensure it remains appropriate for the organization's needs and delivers intended outcomes.
The review examines whether your ISMS is:
Suitable: Aligned with your organization's context, strategy, and business objectives
Adequate: Sufficiently resourced and scoped to protect information assets
Effective: Achieving information security objectives and controlling risks
Management reviews must be documented with retained records showing inputs considered, decisions made, and actions taken.
Required Inputs (Clause 9.3)
Your management review must consider:
Status of Actions from Previous Reviews
Track completion of decisions and action items from the last management review.
Changes in External and Internal Issues
Review updates to the context analysis from Clause 4.1 (external factors like new regulations, cyber threats) and Clause 4.2 (internal changes like mergers, new systems).
Feedback on Information Security Performance
Examine:
Trends in nonconformities and corrective actions
Monitoring and measurement results
Achievement of information security objectives
Performance of controls
Feedback from Interested Parties
Include customer security concerns, regulator feedback, partner requirements, and employee security reports.
Results of Risk Assessment and Risk Treatment Plan Status
Review new or changed risks, effectiveness of risk treatments, and progress on implementing controls.
Opportunities for Continual Improvement
Identify areas where the ISMS can be enhanced based on lessons learned, emerging technologies, or best practices.
Missing any required input can result in a non-conformity during certification audits. Ensure all Clause 9.3 inputs are documented and considered.
Required Outputs
Management review outputs must include decisions and actions related to:
Continual improvement opportunities: Strategic initiatives to enhance the ISMS
Need for changes to the ISMS: Updates to scope, policies, objectives, or controls
Resource needs: Budget, personnel, tools, or training required
Example output: "Approve €50,000 budget for implementing multi-factor authentication (MFA) across all systems by Q3 to address increased phishing risks."
Who Participates
ISO 27001:2022 requires "top management" to conduct the review. This typically includes:
CEO, COO, or equivalent executives
CISO or Information Security Manager (presents findings)
Relevant department heads (IT, Legal, Compliance, HR)
Risk owners for critical assets
Delegate preparation to the ISMS team, but ensure actual decision-makers attend. The review loses value if executives aren't present to make resource and strategic decisions.
Frequency and Timing
While ISO 27001:2022 requires reviews at "planned intervals," best practices recommend:
Annual reviews as a minimum
Semi-annual reviews for mature or high-risk organizations
Additional reviews after major incidents or significant organizational changes
Timing before certification audits to address any gaps
Documentation Requirements
Clause 9.3 requires you to retain documented information as evidence of management reviews. Your records should include:
Meeting agenda showing all required inputs were covered
Attendance list confirming top management participation
Summary of inputs presented (metrics, audit findings, risk changes)
Decisions made and actions assigned with owners and deadlines
Evidence of follow-up on previous actions
Use ISMS Copilot to generate management review agendas, prepare input summaries from your ISMS data, or draft action plans based on review decisions.
Common Mistakes to Avoid
Delegating the review to middle management instead of top executives
Treating it as a formality without meaningful discussion
Missing required inputs from Clause 9.3
Failing to document decisions and actions
Not following up on action items from previous reviews
Related Terms
Internal Audit – Provides key input for management review
ISMS – The system being reviewed
Interested Parties – Source of feedback input
Risk Treatment – Status reviewed in management meetings