Resources · Tools
ISO 27701:2025 Transition Checklist
32 steps in five phases to move your privacy information management system (PIMS) from ISO/IEC 27701:2019 to the 2025 edition. Tick off each step, see the evidence to keep, and download the checklist as an Excel workbook.
TL;DR
Certificates issued against ISO/IEC 27701:2019 must move to the 2025 edition by 31 October 2028. The 2025 edition is a standalone management system with its own Clauses 4 to 10 and three Annex A control tables, so most of the work is remapping and rebuilding your Statement of Applicability.
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Sources: ISO/IEC 27701:2025 · UKAS transition bulletin. Your certification body may set an earlier date, so confirm yours in step 1.2.
0%0 of 32 steps done
1. Plan the transition
0 of 6 doneConfirm dates with your certification body and decide how the PIMS will run.
Evidence to keep
Purchase record or licence for the standard.
ISO/IEC 27701:2025Evidence to keep
Written confirmation or the certification body's transition notice.
ISO/IEC 27706:2025Evidence to keep
Confirmed audit date in writing.
Transition deadlineEvidence to keep
Project plan and the briefing record or minutes.
Clause 5Evidence to keep
Documented decision with the reasons.
Clause 4.3Evidence to keep
Gap list for the work the ISMS covered before.
Clauses 6 to 10, Table A.3Critical for a standalone PIMS
2. Run the gap analysis
0 of 4 doneMap what you have today to the 2025 edition.
Evidence to keep
Mapping table from 2019 references to 2025 references.
Annex FEvidence to keep
Processing inventory showing your role for each processing activity.
Tables A.1 and A.2Evidence to keep
Updated PIMS scope statement.
Clause 4.3Evidence to keep
Gap register with owners and dates.
Clause 6
3. Update the management system
0 of 9 doneThe PIMS now has its own Clauses 4 to 10.
Evidence to keep
Context and interested parties register.
Clauses 4.1 and 4.2Evidence to keep
Context register entry showing the climate change decision.
Clause 4.1Evidence to keep
Approved privacy policy and assigned PIMS roles.
Clause 5Evidence to keep
Privacy risk assessment and risk treatment plan.
Clause 6.1Evidence to keep
Privacy objectives with owners and targets.
Clause 6.2Evidence to keep
Training records, communication plan and document control procedure.
Clause 7Evidence to keep
Operational records for the treatments in the plan.
Clause 8Evidence to keep
Updated audit programme and management review agenda.
Clause 9Evidence to keep
Corrective action procedure and log.
Clause 10
4. Rebuild controls and the SoA
0 of 7 doneMove to the three Annex A tables.
Evidence to keep
Statement of Applicability built on the 2025 tables.
Annex AEvidence to keep
Table A.3 control evidence, or a mapping to ISO 27001 Annex A.
Table A.3Critical for a standalone PIMSEvidence to keep
Control implementation notes referencing Annex B.
Annex BEvidence to keep
Document register showing updated references.
Annex BEvidence to keep
Legal mapping for each privacy law in scope.
Annex DEvidence to keep
Mapping from your controls to ISO/IEC 27018.
Annex EEvidence to keep
List of customer-facing documents to update after certification.
Customer commitments
5. Get audit ready
0 of 6 doneProve the updated PIMS works before the auditor arrives.
Evidence to keep
Training attendance records.
Clause 7.2Evidence to keep
Internal audit report against ISO/IEC 27701:2025.
Clause 9.2Evidence to keep
Management review minutes.
Clause 9.3Evidence to keep
Corrective action records.
Clause 10Evidence to keep
Evidence pack ready to share with the auditor.
Audit preparationEvidence to keep
ISO/IEC 27701:2025 certificate.
Transition audit
Frequently asked questions
When must I move my ISO 27701:2019 certificate to the 2025 edition?
By 31 October 2028. After that date a 2019 certificate is no longer valid. Your certification body may need you to move sooner, so confirm its own dates.
Can the transition happen at my next surveillance audit?
Yes. A transition audit can run with a surveillance visit, a recertification visit or a separate visit. It usually needs extra audit time, so book it early.
Do I still need ISO 27001 to hold ISO 27701:2025?
No. The 2025 edition is a standalone management system standard. If you drop ISO 27001, the risk process, internal audit, document control and the Table A.3 security controls must all run inside the PIMS.
Where do I start the gap analysis?
Start with Annex F of ISO/IEC 27701:2025. It shows where each part of the 2019 edition now sits, so you can map your existing documents and controls to their 2025 homes.
Move to the 2025 edition with a plan
We run the Annex F gap analysis, rebuild your Statement of Applicability on the new tables, and prepare you for the transition audit well before October 2028.