A Strategic Guide to Transitioning from ISO 27701:2019 to the 2025 Update

If your organization has already invested the effort to achieve ISO/IEC 27701:2019 certification, you are well-positioned in the privacy landscape. But with the upcoming release of the 2025 update, a critical question naturally arises: Do we need to start over?

The good news is that the answer is no. The 2025 revision is an evolution, not a revolution. Your existing Privacy Information Management System (PIMS) provides a strong foundation for the transition.

In this post of our series, we will walk you through what’s changing, what’s staying the same, and how to plan a smooth and strategic transition to the new standard.

Your Foundation Remains Strong: What Isn't Changing

Let's start by acknowledging the value of your current program. The core principles of privacy governance that you have already implemented remain central to the new standard.

Here’s what carries over:

• Core Privacy Principles: The fundamental objectives for protecting Personally Identifiable Information (PII) for both controllers and processors are largely preserved.

• Focus on Data Subject Rights: The emphasis on accountability, risk-based processing, and honoring data subject rights is still at the heart of the standard.

• Control Framework: Annex A continues to be the foundation for your control implementation, though it has been consolidated and refreshed for clarity.

• Regulatory Alignment: Your ability to demonstrate alignment with regulations like GDPR remains strong; in fact, the mapping to global laws has been improved.

  
  

You do not need to rebuild your privacy program. You need to realign and enhance it to meet the updated structure and a new set of modern expectations.

Understanding the Key Changes for Your Transition

The 2025 update introduces several meaningful changes designed to make the standard more practical and relevant.

1. A Standalone Structure: ISO 27701 is no longer an extension of ISO 27001. It now includes its own dedicated management system clauses (4–10). This means you will need to update your PIMS documentation to reflect this new, self-contained governance structure.

2. Consolidated and Updated Annex A: The controls for PII controllers and processors, previously in separate annexes, are now unified under a single Annex A. This annex is also updated to align with the modern ISO 27001:2022 control set.

3. New Practical Implementation Guidance (Annex B): A brand new Annex B offers actionable, best-practice guidance for each control, bridging the gap between policy and practice. This is a valuable resource for refining your existing control implementations.

4. Modernized Controls for New Risks: The update introduces approximately 10 new controls focused on emerging risk areas, including AI and automated processing, cloud service privacy, and cross-border data transfers. At the same time, around 50 legacy security controls not specific to privacy have been removed, making the standard leaner.

   
   

The Official Transition Timeline

ISO 27701:2025 is anticipated to be officially published in Q3 2025. Once released, certification bodies are expected to provide a three-year transition period.

This likely gives your organization until 2028 to migrate your certification from the 2019 to the 2025 version. However, we strongly recommend starting the process much sooner, especially if you have a surveillance or recertification audit scheduled in the next 12-18 months.

Your 6-Step Transition Plan

Here is a structured approach to managing the transition smoothly and effectively.

• Step 1: Conduct a Comprehensive Gap Assessment: Once the standard is published, the first step is to evaluate your current PIMS against the new requirements. Use a checklist to compare your existing controls and documentation against the new clause structure, the updated Annex A, and the new controls for AI, cloud, and data transfers.

• Step 2: Update Your Documentation and Governance: Based on your gap assessment, update your core PIMS documentation. This includes revising your PIMS policy to reflect the new standalone structure, updating process documents to incorporate any new controls, and adjusting your risk assessment methodology to include emerging risk areas.

• Step 3: Implement and Validate New or Updated Controls: Address the gaps identified by implementing the necessary technical and procedural safeguards for the new controls. Use the guidance in Annex B as a benchmark to ensure you are meeting the intent of each requirement in practice.

• Step 4: Train Stakeholders and Update Audit Programs: Communicate the changes to your privacy team and other key stakeholders. Provide updated, role-based training where necessary (e.g., for engineering teams working with AI or procurement teams managing cloud vendors). Finally, update your internal audit checklists to reflect the 2025 standard.

• Step 5: Run a Readiness Audit: Before your official audit, conduct a full internal audit against the 2025 standard. This will help you confirm that all changes have been implemented effectively and that your team is prepared for the external assessment.

• Step 6: Schedule Your Transition Audit: Contact your certification body to understand their timeline for offering ISO 27701:2025 audits. Decide whether to transition during your next surveillance audit or at your recertification, and schedule accordingly.

  
  

Beyond Compliance: A Strategic Opportunity

The 2025 update is more than a compliance exercise; it’s a chance to optimize and elevate your privacy program. Use this transition as an opportunity to ask strategic questions:

• Should we decouple our PIMS from our ISMS and manage it as a standalone program?

• Can we use the new focus on AI and cloud governance to build stronger partnerships with our engineering and IT teams?

• How can we leverage our updated certification to build greater trust with customers and partners?

  
  

Evolve Your Program with Confidence

ISO 27701:2025 makes privacy management more practical and current, even for organizations already certified. You don’t need to rebuild; you need to evolve. With a structured plan, this transition can be a significant strategic win that strengthens your resilience to modern privacy risks.

Need guidance planning your transition to ISO 27701:2025?

Straverra offers gap assessments, documentation support, and readiness audits to help you navigate the move from the 2019 to the 2025 version with confidence.