A.5.16·high·Component: Organizational controlsWhat this control requires
The full life cycle of identities shall be managed.
In plain English
The full life cycle of identities shall be managed. In practice, this means you can prove you management management-level controls on a defined cadence.
Why it matters
ISO 27001 certification depends on showing each Annex A control is either implemented or explicitly justified for exclusion in the Statement of Applicability (SoA). Certification bodies sample controls during surveillance audits, and a missing SoA entry — or implementation that doesn't match the SoA wording — is a finding.
This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.
What an auditor looks for
An ISO 27001 lead auditor looks for: (1) an SoA entry covering the control with justification, (2) a documented procedure or policy implementing it, (3) records that prove the procedure runs (logs, tickets, training records) and (4) management-review evidence that effectiveness is monitored.
Within Organizational controls, the assessor will trace your implementation back to the catalogue reference (Annex A A.5.16) and look for objective evidence on the latest two assessment cycles.
How to implement
- Write a short policy stating intent, scope and named owner.
- Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
- Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
- Review on a documented cadence and capture the review in the risk register or compliance tracker.
Operational checklist
- Management. Document the trigger, the owner and the cadence.
- Identity. Document the trigger, the owner and the cadence.
- Access. Document the trigger, the owner and the cadence.
- Scope: management.
Evidence to collect
- Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Identity management.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- ISO/IEC 42001:2023 A.3.2 — AI roles and responsibilities
- SOC 2 (2017 TSC) CC1.5 — Accountability for Internal Control Responsibilities
- NIST SP 800-171 Rev. 3 3.13.4 — Information in Shared System Resources
- CIS Controls v8 6.1 — Establish an Access Granting Process
- ISO/IEC 27701:2025 A.3.8 — Identity management
Related controls in ISO/IEC 27001:2022
- Annex A A.5.33 — Protection of records
- Annex A A.5.2 — Information security roles and responsibilities
- Annex A A.5.18 — Access rights
- Annex A A.8.23 — Web filtering
- Annex A A.5.15 — Access control
- Annex A A.6.1 — Screening
References
- ISO/IEC JTC 1/SC 27 — ISO/IEC 27001:2022
- Catalogue identifier:
Annex A A.5.16
Topics: governance riskidentity accessidentity managementaccess reviewprivileged access