Annex A 5.5: Contact With Authorities

Annex A 5.5 is an operational control. Policy language alone rarely passes an ISO 27001 audit because the auditor needs to see that you can actually reach the right authority under pressure, with the right approvals, and without creating new legal exposure. “Authorities” here can include regulators, supervisory bodies, data protection authorities, law enforcement, sector-specific cyber reporting entities, and local government bodies relevant to your locations and services.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat Annex A 5.5 like a tightly-scoped runbook: define your authority universe, build a maintained contact register, map triggers to the people who decide “notify vs. don’t notify,” and integrate that decision into incident response and legal hold workflows. Your goal is consistent execution: no scrambling for phone numbers, no ad hoc outreach by engineers, and no gaps in evidence when a customer or auditor asks, “How do you contact authorities, and when did you last validate it?”

This page gives requirement-level implementation guidance you can put into production quickly, with the artifacts you need to retain and the exam questions you should expect. ¹

Regulatory text

Control: ISO/IEC 27001:2022 Annex A control 5.5 implementation expectation (Contact With Authorities). ¹

Plain-English interpretation (what the operator must do)

You must identify relevant authorities, establish how to contact them, and define who inside your organization is allowed to make contact and under what conditions. Operationally, this means:

• You can quickly determine which authority is relevant for a given incident, investigation, or legal obligation.
• You have current contact channels (not just a name).
• You control outbound communications to authorities through an approved set of roles (typically Legal, CCO, Privacy, and Incident Response leadership).
• You retain records of contact attempts, communications, and decisions.

This control is about readiness and governance of external communications, not about forcing notification in every incident. Notification obligations come from laws, contracts, and regulators. Annex A 5.5 expects you to be ready to meet those obligations without chaos. ²

Who it applies to

Entity scope

This applies to organizations implementing an ISO/IEC 27001 ISMS, including service organizations supporting customers where incident communications and regulatory reporting are part of delivery expectations. ²

Operational context (where it shows up in real life)

Annex A 5.5 becomes “live” in scenarios such as:

• Security incidents that may trigger regulator or data protection authority notification.
• Suspected criminal activity (fraud, extortion, intrusion) where law enforcement contact is considered.
• Regulatory inquiries, subpoenas, or supervisory exams.
• Sector-specific reporting requirements tied to critical services or regulated customers.
• Cross-border incidents where multiple jurisdictions could be implicated.

If you operate in multiple countries, run cloud services, process personal data, or support regulated customers, your “relevant authorities” list is rarely one agency. Build for routing and decisioning.

What you actually need to do (step-by-step)

Step 1: Assign ownership and decision rights

1. Name a control owner (often the CCO, Security Governance, or Privacy lead).
2. Define authorized communicators:
   • Primary: Legal/GC, CCO, DPO/Privacy Officer (where applicable), Incident Commander.
   • Delegates: specific roles by name/title, with alternates.
3. Define approval gates:
   • When Legal approval is required before contacting any authority.
   • When pre-approved immediate contact is allowed (example: imminent harm, safety issues), and how you document it afterward.

Deliverable: a short “Contact with Authorities” procedure with an approvals matrix.

Step 2: Build an Authority Contact Register (the centerpiece)

Create and maintain a register that includes, for each authority:

• Authority name and jurisdiction
• What it covers (privacy, cyber reporting, financial regulator, law enforcement, etc.)
• Contact channels (portal link, email, phone, emergency line)
• Hours/availability constraints (if known)
• Required identifiers (license number, entity registration, customer ID)
• Internal owner for that relationship
• Notes on required formats (web form, signed letter, counsel-to-counsel)

Practical tip: store this register in a controlled system (GRC tool, secured wiki, or document repository) with versioning and access controls. You need it available during an incident, but not editable by everyone.

Step 3: Map triggers to the register (so it’s executable)

Create a trigger matrix that links common events to authority categories and internal owners. Example triggers:

• “Personal data breach suspected” → Privacy/DPO + Legal → assess authority notification requirements.
• “Ransom demand received” → Incident Response + Legal → decide on law enforcement contact.
• “Regulatory inquiry received” → Legal + CCO → log and manage response deadlines.

Keep the matrix simple enough that an Incident Commander can use it at 2 a.m.

Step 4: Integrate into incident response and legal response workflows

Embed authority contact steps into:

• Incident Response Plan: add a task for “Authority notification decision” and “Authority contact execution,” with required approvals.
• Communications Plan: align external communications so statements to customers, press, and authorities do not conflict.
• Ticketing/Case Management: ensure every authority contact is tracked as a case with timestamps, approvers, and artifacts.
• Legal hold / evidence preservation: coordinate before outreach when the situation may become investigatory.

This is where Annex A 5.5 becomes auditable: the workflow creates consistent records.

Step 5: Validate the control works (tabletop + contact verification)

Run a controlled test that confirms:

• The register is reachable (numbers work, portals accessible, emails valid).
• On-call leaders know where to find it.
• The approvals chain functions under time pressure.

You do not need to send test notices to regulators. Instead, validate internal routing, documentation, and that you could submit via the right channel. Record the test results and remediation actions.

Step 6: Define evidence retention and confidentiality rules

Set rules for:

• Where authority communications are stored (restricted repository)
• Who can access them (need-to-know)
• Retention aligned to your incident record retention and legal requirements
• How to handle privileged communications (counsel involvement, labeling, segregation)

Avoid mixing privileged drafts into broadly accessible incident channels.

Required evidence and artifacts to retain

Auditors typically expect a tight evidence bundle that proves design and operation:

Design evidence

• “Contact with Authorities” procedure/runbook (approved, versioned)
• Authority Contact Register (version history, last review record)
• RACI or approvals matrix (who can contact, who approves)
• Incident Response Plan section showing authority contact decision steps ²

Operating evidence

• One or more completed incident records showing:
  • Trigger assessment
  • Decision to contact (or not contact) an authority
  • Approvals (Legal/CCO)
  • Record of contact attempt and outcome
• Tabletop or simulation results, including lessons learned and remediation tickets
• Periodic control health check record: review completed, issues tracked to closure

Retention/location evidence

• Screenshot or export showing where artifacts live and access restrictions (avoid exposing sensitive content; demonstrate controls)

Common exam/audit questions and hangups

Auditors and customer due diligence teams tend to probe the same failure modes:

1. “Which authorities are relevant to your ISMS scope?”
   Hangup: a generic list that ignores jurisdictions where you operate.

2. “Who is allowed to contact regulators or law enforcement?”
   Hangup: “anyone on the incident team.” That fails governance expectations.

3. “Show me evidence you validated the contact list.”
   Hangup: a contact spreadsheet with no ownership, no last-reviewed date, and no change history.

4. “Show an incident where this operated.”
   Hangup: incidents recorded as chat transcripts with no decision log, no approvals, and no retained communications.

5. “How do you prevent conflicting external messaging?”
   Hangup: PR/customer comms run separately from authority communications.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	How to avoid it
Contact list exists but is stale	Wrong numbers during an incident; auditors see weak operation	Assign a named owner and require periodic review sign-off
No authorization boundaries	Engineers or support staff contact authorities ad hoc	Document allowed roles; route inbound/outbound via Legal/CCO
“Notify authority” step missing from IR	Decision happens verbally; no evidence trail	Add explicit IR tasks and required approvals in the case workflow
No record when you choose not to notify	Audit gap; looks like you forgot	Record the decision, rationale, and approver in the incident file
Privileged content stored in broad channels	Legal risk; discovery exposure	Keep counsel communications in restricted, labeled repositories

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this control, so this page does not cite specific case outcomes. Practically, the risk shows up as:

• missed or late regulatory notifications because no one knew who to contact or who had authority to do it;
• inconsistent statements across customers, regulators, and law enforcement;
• inability to demonstrate control operation during ISO certification audits or customer security reviews.

Annex A 5.5 reduces those risks by forcing repeatable governance around authority communications. ²

Practical execution plan (30/60/90-day)

You asked for speed and operationalization. Use this phased plan.

First 30 days (stand up the control)

• Draft the “Contact with Authorities” procedure: scope, authorized roles, approvals, and documentation rules.
• Build the initial Authority Contact Register for your operating jurisdictions and regulated customer base.
• Add the trigger-to-authority decision matrix.
• Put storage and access controls in place for authority communications.

Success criteria: you can answer “who contacts whom, how, and with what approval” without improvising.

Days 31–60 (integrate into operations)

• Integrate steps into incident response tickets/playbooks and your communications plan.
• Train the incident commander rotation, Legal, Privacy, and Security leads on the workflow.
• Define the minimum evidence bundle for each incident involving authority contact decisions.

Success criteria: every relevant incident produces consistent artifacts with approvals.

Days 61–90 (prove it works and maintain it)

• Run a tabletop that exercises an authority contact decision, including Legal approval, drafting, and record retention.
• Perform a contact register validation (channel verification without sending test notices).
• Start recurring control health checks and track remediation items to closure.

Success criteria: you have test evidence plus a maintenance rhythm that prevents staleness.

Where Daydream fits (earned mention)

Teams often fail Annex A 5.5 on evidence consistency, not intent. If you run Daydream for GRC, treat Annex A 5.5 as a control card with a defined evidence bundle and recurring health checks. That structure makes it easier to produce audit-ready proof without rebuilding the story each time.

Frequently Asked Questions

Do we have to proactively introduce ourselves to regulators to satisfy Annex A 5.5?

No. The control is about having defined contact points and a managed process for contacting authorities when required or appropriate. Your evidence should show readiness, authorization, and records of decisions and actions.

Who should be authorized to contact law enforcement or regulators?

Default to Legal/GC, CCO, and designated incident leadership roles, with named alternates. Document it, and block ad hoc outreach by non-authorized staff through training and incident procedures.

We operate globally. Do we need a separate authority list per country?

You need coverage for jurisdictions relevant to your ISMS scope and operations. In practice, keep one master register with jurisdiction tags and clear routing rules, so responders can filter quickly during an incident.

What evidence satisfies an auditor if we’ve never had to contact an authority?

Show design and readiness: the approved procedure, maintained register with review records, integration into incident response, and a tabletop test record with remediation tracking.

How do we handle conflicts between customer communications and authority communications?

Use a single communications governance path during incidents: align Legal, CCO, Security, and PR/customer teams around approved facts and timelines. Store authority communications separately and restrict access where privilege may apply.

Where should we store the authority contact register so it’s available during an incident?

Store it in a controlled repository with version history and restricted edit permissions, and make it accessible to the incident leadership group. Also ensure it’s reachable during outages (for example, documented offline access method if your primary systems are down).

Footnotes

1. ISO/IEC 27001 overview; ISMS.online Annex A control index

2. ISO/IEC 27001 overview