Navigating the Shift: What the New ISO 27701:2025 Means for Your Privacy Program

The landscape of data privacy is in constant motion. Driven by evolving global laws, the rapid advancement of AI, and the dominance of cloud-native infrastructure, organizations now manage personal data in an environment more complex than ever before.

To keep pace with this new reality, the International Organization for Standardization (ISO) is releasing a major update to its flagship privacy standard: ISO/IEC 27701:2025.

For any organization that processes personal information—from a high-growth startup to a multinational enterprise—the implications of this update will be significant. This article will analyze the core changes, explain why the standard is being overhauled, and provide actionable steps you can take to prepare for a smooth transition.

What Is ISO 27701?

ISO/IEC 27701 is the international standard for managing personal data through a Privacy Information Management System (PIMS). It is designed to help organizations demonstrate compliance with privacy laws like the GDPR and CCPA and build trust with customers by showing a verifiable commitment to protecting personal information.

Until now, ISO 27701 was structured as an extension to ISO 27001, the information security standard. This meant an organization could not achieve ISO 27701 certification without first having an ISO 27001 compliant Information Security Management System (ISMS) in place. In short, a comprehensive security program was a mandatory prerequisite for privacy certification.

Why Is ISO Releasing a New Version?

While the 2019 version of the standard served its purpose, the digital world has changed dramatically. Global privacy regulation has expanded, with dozens of new laws emerging. Technologies like AI, machine learning, and decentralized cloud storage are now mainstream, introducing new risks and responsibilities.

Furthermore, the core structure created a significant barrier. Requiring a full ISMS before addressing privacy was impractical for many organizations, especially those whose primary focus was data protection rather than broad information security. The 2025 version directly addresses these challenges.

"This is the most impactful change in the standard's history, making verifiable privacy management accessible to a much wider range of organizations."

What’s Changing in ISO 27701:2025?

Here is a high-level look at the key changes:

A Standalone, Privacy-First Standard

The most significant change is that ISO 27701 will become a standalone standard. This means you can implement and certify your PIMS independently, without needing ISO 27001 certification first. This removes a major barrier for organizations that are focused on privacy but don't need the full scope of an ISMS.

A Full, Integrated Management System

The new version includes its own dedicated Clauses 4–10, covering all the essential ISO management system components: context, leadership, planning, support, operations, performance evaluation, and continual improvement, all through a privacy-first lens.

Modernized and Streamlined Privacy Controls

The control set (the specific requirements you must implement) is receiving a major refresh. It will be:

• Updated to reflect modern risks like cloud privacy, AI governance, and cross-border data transfers.

• Streamlined into a single Annex with clear distinctions for data controllers and processors.

• Aligned with the latest ISO 27001:2022 control structure, ensuring seamless integration for organizations that choose to pursue both standards.

  
  

Practical Implementation Guidance

A common criticism of the 2019 edition was its lack of practical advice. The 2025 update fixes this with a new Annex B, which will provide clear, step-by-step guidance on how to meet each requirement, reducing ambiguity and implementation costs.

Why This Update Matters for Your Business

This is more than a technical refresh; it's a strategic opportunity. By decoupling privacy from security certification, ISO is acknowledging that privacy is its own distinct discipline. This allows for a more focused, precise, and accessible approach to building a certifiable privacy program. The key takeaway is that this is the most business-friendly and privacy-centric version of the standard yet.

When Will It Be Released?

ISO 27701:2025 is currently in its final approval stage. The Final Draft International Standard (FDIS) is expected to be submitted in the coming months, with official publication anticipated in Q3 2025.

Once published, certification bodies will begin offering audits under the new version. A transition period of three years is expected for companies already certified to the 2019 edition.

How to Prepare for the Transition

Proactive organizations can begin preparing now to ensure a seamless adoption of the new standard.

1. Stay Informed: Monitor the official ISO publication schedule for updates on the final release date.

2. Initiate Internal Dialogue: Brief your privacy, legal, and IT leadership on these changes to align your compliance roadmap for the coming year.

3. Conduct a Gap Analysis: Review your current PIMS against the anticipated changes, particularly the move to a standalone structure and the new controls for AI and cross-border data.

4. Plan Your Transition or Implementation: Whether you are starting from scratch or migrating from the 2019 version, now is the time to build your project plan.

   
   

Build a Future-Proof Privacy Program

The shift to ISO 27701:2025 is an opportunity to strengthen your privacy posture and build greater trust with your customers.

For a more tailored discussion, schedule a complimentary readiness assessment with one of our certified privacy experts to map out your specific transition plan.

About the Author: Aaron Manthe has over 15 years of experience and certifications including CIPP/E and CISM, Aaron helps global organizations build and certify robust security and privacy programs that drive business growth.