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ISO/IEC 27701: Moving Your 2019 PIMS Certificate to the 2025 Standalone Edition

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By NHI Mgmt Group, edited by Lalit Choda Updated 27 October 2026 12 min read
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ISO/IEC 27701:2025 turned the privacy information management system (PIMS) from an extension of ISO/IEC 27001 into a standalone management system standard, and every organisation certified to the 2019 edition now has a fixed window to transition. ISO published the second edition on 14 October 2025 and lists the 2019 edition as withdrawn. Accreditation bodies have set 31 October 2028 as the date by which certification bodies must move all certified clients to the 2025 edition. This guide explains what changed, what the transition deadlines are, how to run a gap analysis and transition audit, where identity and non-human identity controls fit, and how to map the new PIMS to ISO/IEC 27001, GDPR and NIST. It is for privacy managers, ISMS owners and auditors. The standard itself is introduced in the ISO/IEC 27701 Privacy Information Management Guide; this page covers the move to 2025.

Status checked 27 October 2026 on iso.org and accreditation body notices (SAC Singapore and SCC Canada). Check your own certification body's transition rules, which may set earlier internal dates.

Key takeaways

  • Standalone, not an extension: ISO describes the 2025 edition as an independent management system standard that can be used alone, while still aligning with an ISO/IEC 27001 ISMS.
  • Fixed deadlines: certification bodies must complete their own transition by 31 October 2027 and transition all certified clients by 31 October 2028, according to the SAC and SCC notices.
  • A new certification body standard: ISO/IEC 27706:2025 replaces ISO/IEC TS 27006-2:2021 for bodies that audit and certify PIMS.
  • No ISMS certificate needed first: SCC notes that clients no longer need a certified ISMS before applying for PIMS certification.
  • The work is mostly management system work: SCC lists the harmonised structure, stronger leadership, governance, performance evaluation, privacy risk management and climate change considerations, and clarified controller and processor controls.

What it is and who it applies to

ItemISO/IEC 27701:2019ISO/IEC 27701:2025
Status (iso.org)WithdrawnPublished, edition 2, October 2025 (64 pages)
Full titleExtension to ISO/IEC 27001 and ISO/IEC 27002 for privacy information managementInformation security, cybersecurity and privacy protection: Privacy information management systems, Requirements and guidance
Relationship to ISO/IEC 27001Extension: PIMS built on an ISMSStandalone management system standard that aligns with an existing ISMS
StructureClauses extending 27001 and 27002 textISO harmonised structure (per SCC)
AudiencePII controllers and processorsPII controllers and processors
Certification body standardISO/IEC TS 27006-2:2021ISO/IEC 27706:2025, following the structure of ISO/IEC 17021-1
CommitteeISO/IEC JTC 1/SC 27

Who must act: any organisation holding a 2019 PIMS certificate, any organisation planning PIMS certification (new certificates should be to 2025 once the certification body has transitioned), and processors whose customers ask for 27701 evidence in contracts.

Who does not have to act: organisations using 27701 informally as a reference framework have no deadline, although the 2019 text is withdrawn and should be replaced in internal policies.

Transition timeline

DateMilestoneSource
14 October 2025ISO/IEC 27701:2025 and ISO/IEC 27706:2025 publishediso.org; SAC
December 2026Accredited PIMS certification bodies submit transition plans, gap analyses and evidence to SCC (Canada), unless SCC directs otherwiseSCC
31 October 2027Accredited certification bodies complete their own transition (to 27706:2025)SAC; SCC
31 October 2028Certification bodies must have transitioned all certified clients to 27701:2025SAC; SCC

SCC states that certifications to the 2025 edition can begin once the certification body's ISO/IEC 27706 transition is complete. In practice, ask your certification body now when it expects accreditation to 27706 and whether it will transition you at a surveillance audit, a recertification audit or a special visit. Plan to transition well before October 2028: audit slots near the deadline will be scarce, and a lapsed 2019 certificate cannot simply be renewed.

SAC also notes that certification bodies receive separate standalone accreditation for PIMS and ISMS after transition, which reflects the decoupling of the two schemes.

Structure and key requirements

Because the 2025 edition follows the harmonised structure, its requirements clauses read like any other ISO management system standard: context of the organisation, leadership, planning, support, operation, performance evaluation and improvement (clauses 4 to 10 in the harmonised structure). The practical differences for a 2019 holder:

  • Own scope and context: the PIMS needs its own scope statement, interested parties (data subjects, supervisory authorities, customers acting as controllers) and internal and external issues, rather than borrowing the ISMS scope.
  • Leadership and policy: a privacy policy and roles approved by top management, including whoever acts as the privacy lead or DPO.
  • Privacy risk management: SCC highlights strengthened privacy risk management. Expect to show a privacy risk assessment and treatment process that considers risks to individuals, not only information security risk to the organisation.
  • Climate change consideration: as with other harmonised structure standards that adopted the climate action amendment, determine whether climate change is a relevant issue (often documented as not significant for privacy, with reasoning).
  • Performance evaluation: privacy objectives with measurable results, internal audit and management review of the PIMS in its own right.
  • Controller and processor controls: SCC states that controller and processor controls were clarified. Re-map your Statement of Applicability against the control set in the published text rather than assuming the 2019 numbering carries over.

Integrated or separate? If you already run an ISO/IEC 27001:2022 ISMS, an integrated management system (shared document control, internal audit and management review) is usually cheaper to run. A separate PIMS suits organisations whose privacy scope is wider or narrower than the ISMS scope, or processors who want PIMS certification without an ISMS certificate.

Identity and NHI requirements

27701 does not name identity products, but most PII controls are enforced through identity and access management. These are the areas auditors test, and where non-human identities are usually the gap:

PIMS concernHuman identity evidenceNon-human identity evidence
Access to PII limited to purposeRole-based access to PII stores; quarterly access reviewsService accounts and API keys reading PII listed with owner and purpose; scopes limited to required tables or fields
Processor obligations to customersSupport staff access to customer data logged and approvedIntegration tokens into customer tenants scoped and revocable; inventory per customer
Disclosure to third parties and subprocessorsApproval workflow for data sharingOAuth apps and SaaS connectors with PII access reviewed; unused grants removed
Retention and deletionAdministrators who can bypass retention controlled through PAMDeletion and archive jobs run under dedicated identities with logged actions
Logging of PII accessUser access logs retained and reviewedApplication and agent access to PII attributed to a specific workload identity, not a shared account

AI agents and copilots that query PII are processing operations in their own right: record their purpose, the identity they run under and the data they can reach. See the Data Access Governance Guide and the DSAR Guide: Handling Data Subject Requests for the operational processes auditors sample.

Implementation steps

  1. Buy and read the 2025 text (ISO, or your national standards body) and confirm with your certification body its 27706 accreditation date and transition method.
  2. Gap analysis: compare the current PIMS against each 2025 clause and control. Mark items as unchanged, re-worded, new, or moved. Typical new work: standalone scope, context, privacy objectives, privacy risk process, and climate consideration.
  3. Decide integrated or separate and update the management system manual accordingly.
  4. Update the privacy risk assessment to cover risks to PII principals, using your existing DPIA method where it fits.
  5. Rebuild the Statement of Applicability against the 2025 control set, with justification for exclusions and links to evidence.
  6. Update policies and procedures that cite 2019 clause numbers; update contracts and customer assurance packs that reference "ISO/IEC 27701:2019".
  7. Run an internal audit against the 2025 edition and a management review that records the transition decision and resources.
  8. Transition audit with the certification body, then close any nonconformities within its stated timescales.

Gap analysis worksheet. Record each requirement in a register like the one below so the transition audit can trace every change:

2025 requirement areaCurrent 2019 evidenceGap ratingAction and owner
PIMS scope and contextShared ISMS scope statementNewDraft standalone scope with controller and processor roles; privacy lead
Privacy objectivesISMS objectives with one privacy KPIChangedSet measurable PIMS objectives; management review to approve
Privacy risk processISMS risk register, DPIAs held separatelyChangedLink DPIA outputs to a PIMS risk treatment plan; risk owner
Climate change considerationNoneNewDocument relevance assessment in context analysis
Controller and processor controls2019 SoAChangedRe-map SoA to 2025 control set; compliance team
Internal auditCombined ISMS audit programmeChangedAdd PIMS audit criteria to programme; internal audit lead

Controllers and processors decide differently. A processor certifying mainly to satisfy customer due diligence should prioritise the processor controls, subprocessor management and customer-facing evidence, and can now certify the PIMS without an ISMS certificate. A controller should prioritise lawful basis records, data subject rights handling and DPIA integration, because regulators and data subjects test those first. Organisations that act as both, which is common for SaaS providers, must record the role for each processing activity in scope, since auditors check that the right control set is applied to each.

Rollback and continuity: keep the 2019 certificate and documentation set under version control until the certification body issues the 2025 certificate. If the transition audit raises major nonconformities, the existing certificate remains the reference for customers until they are closed, provided it has not expired.

Small versus large organisations: a small processor with a single product can usually complete the gap analysis in a few weeks and transition at its next surveillance audit. A multinational controller with country-specific privacy teams should run a pilot entity first, then roll the updated manual and SoA out by region, and keep the 2019 certificate valid until the transition audit is passed.

Evidence and assessment

Evidence itemWhat auditors look for
PIMS scope and contextStandalone scope, interested parties, controller or processor role per processing activity
Privacy policy and rolesTop management approval, named privacy lead, communication to staff
Privacy risk assessment and treatmentRisks to individuals, treatment decisions, owners, links to DPIAs
Statement of ApplicabilityAll 2025 controls addressed, justified exclusions, evidence references
Records of processingCurrent, complete and consistent with the SoA; see the Data Mapping and ROPA Guide
Data subject request recordsTimeliness, verification, outcomes
Supplier and subprocessor recordsContracts, assessments, transfer mechanisms
Internal audit and management reviewAgainst the 2025 edition, with actions tracked

Metrics that show the PIMS is working: percentage of processing activities with a current risk assessment; DSAR completion within the statutory deadline; number of non-human identities with PII access and no owner (target zero); supplier assessments overdue; internal audit findings closed on time.

Mapping to other frameworks

PIMS areaISO/IEC 27001:2022GDPRNIST
Privacy policy and rolesClause 5; A.5.1, A.5.2Art. 24, Arts. 37-39 (DPO)CSF 2.0 GV.PO-01, GV.RR-02
Privacy risk assessmentClause 6.1Art. 35 (DPIA)SP 800-53 RA-8 Privacy Impact Assessments
Records of processingA.5.9 Inventory of informationArt. 30CSF 2.0 ID.AM-07
Access to PIIA.5.15, A.5.18, A.8.3Art. 32SP 800-53 AC-6; CSF 2.0 PR.AA-05
Privacy and protection of PIIA.5.34Art. 5, Art. 25SP 800-53 PT-2, PT-3
Processors and suppliersA.5.19 to A.5.22Art. 28CSF 2.0 GV.SC-05

See the GDPR Compliance Guide for Security Teams. A 27701 certificate supports, but does not by itself prove, GDPR compliance.

Common pitfalls

  • Waiting for the deadline: transition audits cluster in 2028 and certification bodies run out of auditor time.
  • Copying the ISMS scope: the PIMS scope must reflect where PII is processed and in which role, which often differs from the ISMS boundary.
  • Carrying 2019 control numbers forward: SoAs and contracts that cite old clause references confuse auditors and customers.
  • Information security risk only: a risk register that lists threats to the company but not harms to individuals will not satisfy strengthened privacy risk requirements.
  • Ignoring non-human access to PII: service accounts, integrations and AI agents with broad PII read access and no owner are a frequent audit finding.
  • Assuming certificate equals compliance: regulators assess GDPR obligations directly.

Practitioner checklist

  • Confirm your certification body's 27706 accreditation date and transition approach in writing.
  • Obtain the 2025 text and complete a clause-by-clause gap analysis.
  • Decide integrated or separate management system and document the decision.
  • Write a standalone PIMS scope, context and interested parties analysis.
  • Update the privacy risk assessment to cover risks to individuals.
  • Rebuild the Statement of Applicability against the 2025 controls.
  • Inventory human and non-human identities with PII access, with owner and purpose.
  • Update policies, contracts and assurance packs that cite the 2019 edition.
  • Run an internal audit and management review against 2025 before the transition audit.
  • Book the transition audit well before 31 October 2028.

Standards and references

Related NHI Mgmt Group resources: ISO/IEC 27701 Privacy Information Management Guide · GDPR Compliance Guide for Security Teams · Data Mapping and ROPA Guide · Security Standards Tracker. This guide summarises the ISO/IEC 27701:2025 transition and is not legal advice.

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NHIMG Editorial Note
Researched and written by the NHI Mgmt Group editorial team using AI tools, under the editorial direction of Lalit Choda. Facts are drawn from the sources listed on this page and checked by our automated quality process. Last updated 27 October 2026. Spotted an error? Use our contact page.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM and Agentic AI security. nhimg.org

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