ISMS Copilot
Glossary

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.

Small organizations often have the ISMS implementer in top management, so the same person may conduct the management review. ISO 27001 doesn’t prohibit this, but it creates a segregation of duties risk. Record the risk in your risk register, document the decision to accept or treat it, and define mitigation actions (e.g., future delegation of control ownership, external input, or periodic independent checks).

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

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