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Step 5 · ISO/IEC 27005:2022, Clause 8

ISO 27005 risk treatment plan: from options to acceptance

Treatment turns a ranked list of risks into decisions and actions. Clause 8 of the standard follows clause 6.1.3 of ISO/IEC 27001 step by step: select an option, determine the controls, compare them with Annex A, produce the statement of applicability, formulate the plan, then have it approved by the risk owners, who accept what remains.

Updated on · 7 min read

Clause
8, Information security risk treatment process
Participants
Risk owners, CISO, CIO, management
Deliverables
Statement of applicability, treatment plan, accepted residual risks
Guide chapters
  1. Applying ISO 27005
  2. Context and risk criteria
  3. Identify risks
  4. Analyse risks
  5. Evaluate risks
  6. Treat risks
  7. Monitor and review
  8. ISO 27001 and ISO 31000
  9. ISO 27005 and EBIOS RM
  10. Glossary

In brief

  1. Clause 8 chains five activities: selecting treatment options (8.2), determining all the controls that are necessary (8.3), comparing them with Annex A of ISO/IEC 27001 (8.4), producing the statement of applicability (8.5) and formulating the treatment plan (8.6).

  2. There are four options: reduce the risk through controls, avoid it, share it with a third party or retain it knowingly. They can be combined.

  3. The comparison with Annex A acts as a safety net: it checks that no necessary control has been overlooked. It does not oblige you to adopt all 93 controls.

  4. The plan is approved by the risk owners (8.6.2), who accept the residual risks (8.6.3). Since the 2022 edition, acceptance is the conclusion of treatment.

  5. A residual risk above the criteria is not forbidden: it calls for an explicit, reasoned and signed decision at the right level.

Select a treatment option

For each risk to be treated, the owner selects one or more options (8.2). The standard describes four; the labels vary between editions and translations, the idea stays the same.

The four treatment options
OptionWhat it meansExampleWhat to watch
Reduce (modify the risk)Put in place or strengthen controls that lower the likelihood or the consequencesMulti-factor authentication, segmentation, offline backupsThe real effectiveness of the control, to be checked
AvoidGive up the activity or practice that creates the risk, or remove its sourceRemove a permanent remote accessThe new risk the alternative sometimes creates
ShareHave part of the risk borne by a third party: insurance, contract, outsourcingCyber insurance, liability clauseAccountability stays with the organisation; the third party itself becomes a risk source
RetainKeep the risk as it is, through an informed decisionLow risk, disproportionate cost of treatmentThe decision must be recorded and reviewed

Determine the controls, then compare them with Annex A

Subclause 8.3 asks you to determine all the controls that are necessary to implement the options selected. They can come from any source: Annex A of ISO/IEC 27001, detailed by ISO/IEC 27002, a sector framework, guides from national agencies, or controls designed for your case. You go from the risk to the control, not the other way round.

Subclause 8.4 then asks you to compare these controls with those in Annex A of ISO/IEC 27001:2022. This is the requirement of clause 6.1.3 c): verifying that no necessary control has been omitted. Annex A plays the role of a checklist. If one of its 93 controls addresses a risk you had underestimated, you add it; if it addresses none of your risks and none of your obligations, you exclude it and justify the exclusion.

Diagram of the ISO/IEC 27005:2022 treatment process. Five cards follow one another: 8.2 select the options (reduce, avoid, share, retain); 8.3 determine the necessary controls; 8.4 compare with Annex A of ISO/IEC 27001 to check that no control is omitted; 8.5 produce the statement of applicability; 8.6 formulate the treatment plan. Then come two decisions by the risk owners: approve the plan, then accept the residual risks. At the bottom, the example of risk R1: level 12 before treatment, level 6 after, accepted by the executive committee.
Treating a risk, from option to acceptance: five activities of Clause 8 and two decisions by the risk owners.

The statement of applicability

Subclause 8.5 deals with the statement of applicability (SoA), a document required by ISO/IEC 27001. It lists the necessary controls, justifies their inclusion, states whether they are implemented and justifies the exclusion of the Annex A controls that are not adopted. It is derived from risk treatment: an SoA written before the assessment, by ticking off Annex A, reverses the logic the auditor checks.

Formulate the risk treatment plan

Subclause 8.6 deals with the plan: its formulation (8.6.1), its approval by the risk owners (8.6.2) and the acceptance of the residual risks (8.6.3). The plan says, for each risk to be treated, what will be done, by whom and by when.

What a line of the treatment plan contains
HeadingContent
Risk addressedReference and reminder of the scenario, current level
OptionReduce, avoid, share, retain, or a combination
ControlsActions to carry out, with their link to Annex A where relevant
Person responsible and deadlineA named person, a date, the resources allocated
Expected residual riskConsequences, likelihood and level estimated once the controls are in place
Follow-upProgress status, evidence of completion, way of checking effectiveness

A realistic plan ranks the actions: those that reduce the risk a great deal for a moderate effort go first. Until a control is in place, the risk stays at its initial level; the plan must therefore say what is done in the meantime, for example a temporary control or closer monitoring.

Approve the plan and accept the residual risks

The residual risk is the one that remains after treatment. It is estimated with the same scales as the initial risk, then compared with the acceptance criteria. ISO/IEC 27001 (clause 6.1.3 f) requires you to obtain the risk owners' approval of the plan and their acceptance of the residual risks.

  • Approval of the plan commits the owner on the means: budget, availability of teams, constraints accepted by the owner's activity.
  • Acceptance of the residual risk is a separate decision: the owner acknowledges what will remain once the plan is carried out, and takes responsibility for it.
  • If the residual risk exceeds the criteria, there are two routes: extend the treatment, or accept it by exception, at the level of management provided for in the criteria, with a reason and a review date.
  • Everything is written down: who accepted what, when, on the basis of what information. This is the documented information the auditor will ask for.

Running example: Mécanique Vauclair's treatment plan

Extract from the treatment plan (fictitious example)
Ref.OptionControlsResidual riskDecision
R1 Ransomware through remote maintenanceReduce, shareRemote maintenance access opened on request, named accounts with multi-factor authentication; separation of the workshop and office networks; offline backups tested every quarter; cyber insuranceConsequences 3, likelihood 2: 6, mediumAccepted by the executive committee, annual review
R2 Theft of a customer's drawingsReduceAccess to drawings limited to the designers on the project; multi-factor authentication on email; phishing awarenessConsequences 4, likelihood 1: 4, mediumAccepted by the executive committee
R3 Administration error on the ERPReduceChange procedure with prior backup and test; test environmentConsequences 2, likelihood 1: 2, lowAccepted by the CIO

Frequently asked questions

What is a risk treatment plan?

It is the document that says, for each risk to be treated, which option is chosen, which controls will be put in place, by whom, by when and with what expected residual risk. ISO/IEC 27001 requires it (clause 6.1.3 e), and ISO/IEC 27005 describes its formulation, its approval by the risk owners and the acceptance of residual risks.

What are the risk treatment options?

There are four: reduce the risk by putting controls in place, avoid it by giving up the activity or removing its source, share it with a third party through a contract or insurance, or retain it through an informed decision. Several options can be combined for the same risk.

Do you have to apply every control in Annex A?

No. Controls are determined from risk treatment. Annex A of ISO/IEC 27001 is then used to check that no necessary control has been omitted. An Annex A control can be excluded, provided the exclusion is justified in the statement of applicability.

Who accepts the residual risks?

The risk owners. ISO/IEC 27001 requires you to obtain their approval of the treatment plan and their acceptance of the residual risks. When the residual risk exceeds the acceptance criteria, the decision goes up to the level provided for in those criteria, often top management, and its reasons are given in writing.

Can you accept a risk above the criteria?

Yes, through an explicit decision. Acceptance criteria can provide for a risk above the threshold to be accepted at a higher level of management, for a limited period or with a commitment to treat it later. What is not acceptable is a risk that is kept without anyone having decided it.

Sources

This chapter summarises and rephrases the official publications below. If in doubt, the official text prevails.

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