Annex A 5.9: Inventory of Information and Other Associated Assets

Annex a 5.9: inventory of information and other associated assets requirement means you must maintain a current, owned inventory of information and supporting assets (systems, devices, services, locations, media) so you can apply the right security controls, manage risk, and prove governance during audits (ISO/IEC 27001 overview). Operationalize it by defining asset classes, assigning owners, setting update triggers, and producing audit-ready evidence.

Key takeaways:

• Maintain an inventory that covers information and the assets that store, process, or transmit it, with clear ownership and status.
• Tie the inventory to security outcomes: classification, access control, retention, backup, encryption, and third-party management.
• Treat inventory maintenance as an operating control with triggers, review cadence, and a defined evidence bundle.

A functioning ISMS depends on knowing what you have, where it lives, and who is accountable for it. Annex A 5.9 is the control that forces that discipline: an inventory of information and other associated assets that stays current as your environment changes (ISO/IEC 27001 overview; ISMS.online Annex A control index). For a CCO, GRC lead, or compliance operator, the goal is not to build a perfect CMDB. The goal is to build a reliable governance mechanism that (1) captures the right minimum fields, (2) assigns real owners, (3) stays updated through defined events, and (4) links directly to the controls auditors care about.

This requirement becomes urgent in common situations: rapid SaaS adoption, M&A, cloud migrations, decentralized IT, and heavy third-party dependency. Those situations create “unknown assets,” and unknown assets become unmanaged risk: unreviewed access, data sprawl, missed patching, and unclear breach scope. Annex A 5.9 gives you a defensible, auditable way to reduce that uncertainty.

Below is requirement-level implementation guidance you can execute quickly: scope, steps, roles, evidence, audit questions, and a practical plan to get to a stable operating rhythm without boiling the ocean.

Regulatory text

Framework excerpt (provided): “ISO/IEC 27001:2022 Annex A control 5.9 implementation expectation (Inventory of Information and Other Associated Assets).” (ISO/IEC 27001 overview; ISMS.online Annex A control index)

What an operator must do: Maintain an inventory that identifies information and the assets associated with it, keep it accurate as changes occur, and use it to drive consistent protection. In practice, auditors expect (a) documented scope, (b) defined asset/information types, (c) ownership, (d) lifecycle status, and (e) evidence that the inventory is maintained as an operating control rather than a one-time spreadsheet exercise (ISO/IEC 27001 overview).

Plain-English interpretation (what this control is really asking for)

You need a living list of:

• Information assets (datasets, records, repositories, reports, code, configurations, logs) and
• Associated assets that store/process/transmit that information (applications, cloud services, servers, endpoints, databases, network components, identities, removable media, and third-party services),

…with enough detail to answer basic governance questions fast:

• What is it?
• Who owns it?
• Where is it?
• What data sensitivity applies?
• What security controls apply?
• Is it active, retired, or pending decommission?
• What third parties touch it?

If you cannot answer those quickly, you will struggle to justify control coverage across access control, cryptography, backup, logging, incident response, and third-party risk management.

Who it applies to (entity + operational context)

Applies to: Organizations implementing ISO/IEC 27001:2022, especially service organizations with customer-facing systems and shared responsibility models (ISO/IEC 27001 overview).

Operational contexts where Annex A 5.9 becomes a high-friction audit item:

• Cloud-first environments where assets spin up/down frequently.
• SaaS-heavy stacks where “systems of record” exist outside corporate infrastructure.
• Product organizations shipping frequently, creating new services, data stores, and pipelines.
• Regulated or customer-assured businesses where due diligence asks for asset lists, data flow summaries, and third-party subprocessor detail.

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

Use this as a runbook. Your goal is “complete enough to manage risk” plus “auditable.”

Step 1: Define scope boundaries (ISMS scope aligned)

• List the business units, products, environments, and regions in scope for the ISMS.
• Decide which inventories must be in-scope: production only, or production + corporate + SDLC.
• Write down inclusions/exclusions and the rationale so you can defend it during audit (ISO/IEC 27001 overview).

Output: Inventory scope statement (1–2 pages) mapped to ISMS scope.

Step 2: Decide what counts as an “information asset” and an “associated asset”

Create simple categories your teams can apply consistently.

Recommended minimum categories

• Information: customer data, employee data, financial data, security telemetry, source code, configurations/secrets, operational runbooks.
• Associated assets: applications/services, data stores, endpoints, servers, cloud accounts/projects/subscriptions, identity stores, CI/CD tooling, third-party services, backup repositories.

Output: Asset taxonomy and definitions (short, operational).

Step 3: Set the required fields (minimum viable inventory record)

Pick fields you can actually maintain. A typical audit-ready record includes:

Field	Why it matters
Asset name + unique ID	Prevents duplicates; enables traceability
Asset type/category	Drives control applicability
Business owner	Accountable for risk acceptance and lifecycle
Technical owner/custodian	Accountable for implementation and fixes
Data classification / sensitivity	Drives encryption, access, retention
Location	Cloud region, account, network zone, physical site
Environment	Prod / staging / dev; affects control depth
Third-party involvement	Supports third-party risk and subprocessors
Lifecycle status	Active / planned / retiring / retired
Links to evidence	Diagrams, tickets, configs, monitoring, backups

Output: Inventory schema (spreadsheet columns or GRC/CMDB fields).

Step 4: Assign ownership and operating cadence

Auditors look for clear accountability (ISO/IEC 27001 overview). Put names to roles:

• Control owner (GRC/InfoSec): owns the requirement, writes the procedure, runs health checks.
• Asset owners (business leaders): approve classification and intended use; accept risk.
• Custodians (IT/Engineering): keep technical details current; implement required controls.

Define how the inventory stays current:

• Triggered updates (see Step 5)
• Periodic review (owner attestation or automated reconciliation)

Output: RACI + documented procedure.

Step 5: Define inventory update triggers (the “keep it current” mechanism)

Your inventory fails when it only updates during audits. Use triggers tied to how work actually happens:

High-signal triggers

• New system/service approved through architecture review
• New SaaS procurement or third-party onboarding
• New cloud account/subscription/project creation
• New data store or pipeline creation
• Major change ticket (network changes, IAM model changes)
• Decommission/retirement request
• Incident postmortem identifies an unknown asset

Mechanics

• Require an inventory record (or update) as an exit criterion in the workflow.
• Use a ticket template that captures required inventory fields.
• Automate discovery where possible (cloud inventory exports), but keep ownership and classification as human decisions.

Output: “Inventory update required” gates in ITSM/procurement/SDLC.

Step 6: Link the inventory to the controls that depend on it

Annex A 5.9 is a dependency control. Show that connection:

• Access control: inventory record points to IAM model / system roles
• Cryptography: encryption requirement based on classification/location
• Backup: RPO/RTO expectations by asset category
• Logging/monitoring: required telemetry sources by asset
• Vulnerability management: patching ownership and SLA by asset type
• Third-party risk: list of third parties that store/process data for the asset

Output: Control-to-inventory mapping (a simple matrix is enough).

Step 7: Create a minimum evidence bundle (audit-ready)

Treat inventory maintenance like an operating control with repeatable evidence (ISO/IEC 27001 overview).

• Inventory export (dated) showing required fields
• Sample change tickets showing updates occurred due to triggers
• Owner attestation record (sign-off) or automated reconciliation report
• Exceptions log (assets not yet fully recorded) with remediation dates
• Control health check results and closure evidence for findings

Output: Evidence pack stored in your audit repository.

Step 8: Run control health checks and track remediation

A practical health check:

• Find assets missing owner, classification, location, or lifecycle status.
• Identify “unknown” third-party services discovered outside procurement.
• Confirm retired assets are removed or clearly marked and controls adjusted.

Track to closure with tickets and due dates (ISO/IEC 27001 overview).

Output: Health check report + remediation tracker.

Required evidence and artifacts to retain

Keep artifacts that prove both design and operation:

Control design artifacts

• Inventory policy/standard and procedure (how assets are identified, recorded, reviewed) (ISO/IEC 27001 overview)
• Asset taxonomy and required field definitions
• RACI and owner assignment record
• Update trigger list and workflow gating (templates)

Operating evidence

• Inventory snapshot/export with timestamp and version history
• Change samples (procurement approvals, architecture reviews, decommission tickets) showing inventory updates
• Periodic review/attestation evidence (sign-off or reconciliation output)
• Exceptions register and remediation tickets
• Meeting notes or change advisory board outputs that reference inventory updates (if applicable)

Common exam/audit questions and hangups

Expect auditors and customer assessors to probe these areas:

1. “Show me the inventory for the ISMS scope.”
   Hangup: You provide an IT asset list but no information assets, or the reverse.

2. “How do you know it’s complete?”
   Hangup: No discovery method, no reconciliation, no trigger-based updates.

3. “Who owns this system and this dataset?”
   Hangup: Owner fields exist but point to shared mailboxes or former employees.

4. “How does classification drive controls?”
   Hangup: Classification exists but does not change encryption, retention, or access decisions.

5. “How do you handle third-party hosted processing?”
   Hangup: SaaS tools are missing from the inventory and not tied to third-party due diligence.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating this as a one-time spreadsheet for certification.
   Fix: Build triggers into procurement and change management so updates happen as work happens.

2. Mistake: Only inventorying hardware and servers.
   Fix: Include SaaS, cloud resources, identities, code repos, and data pipelines as associated assets.

3. Mistake: No lifecycle status, so nothing ever gets retired.
   Fix: Add “retiring/retired” statuses and require decommission tickets to update the record.

4. Mistake: “Owner” is nominal and not accountable.
   Fix: Define owner responsibilities: approve classification, approve risk exceptions, sponsor remediation.

5. Mistake: Inventory exists, but controls are not mapped to it.
   Fix: Create a short control dependency matrix that references the inventory ID as the join key.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this control. Practically, Annex A 5.9 failures increase exposure because you cannot demonstrate governance over data locations, third-party processing, or control coverage during incidents and audits (ISO/IEC 27001 overview). The operational risk is straightforward: unknown assets bypass security requirements, and unknown information locations slow containment and notification decisions.

Practical 30/60/90-day execution plan

Use phases rather than day-count promises. Your speed depends on environment complexity and tooling.

First 30 days (establish the control, ship the minimum viable inventory)

• Confirm ISMS scope and write inventory scope boundaries.
• Publish the inventory schema and taxonomy.
• Stand up the inventory repository (GRC tool, CMDB, or controlled spreadsheet) with version control.
• Assign control owner and initial asset owners for top systems.
• Populate the initial list for the most critical assets (customer-facing systems, core data stores, identity platforms, key third-party services).

Days 31–60 (make it operational: triggers, workflow gates, evidence)

• Add inventory update steps to procurement and third-party onboarding workflows.
• Add inventory update steps to architecture review / change management templates.
• Define the evidence bundle and start collecting it in an audit folder.
• Run your first health check; open remediation tickets for missing fields and unknown assets.

Days 61–90 (stabilize and prove sustained operation)

• Perform owner attestation or reconciliation review and record sign-offs.
• Tighten links to dependent controls (access, encryption, backup, logging).
• Formalize exception handling (temporary unknowns with remediation dates).
• Prepare an auditor-ready walkthrough: pick a sample asset, show creation/update evidence, show how classification drives controls.

How Daydream fits (when you need operational lift)

If your friction is less “what fields do we track?” and more “how do we prove this runs every time,” Daydream helps by turning Annex A 5.9 into an owned control card with trigger events, execution steps, and an evidence checklist. That structure reduces audit scramble because you can produce the same evidence bundle each cycle and show remediation to closure (ISO/IEC 27001 overview).

Frequently Asked Questions

Does Annex A 5.9 require a CMDB?

No specific tool is mandated by ISO/IEC 27001. You need an accurate, maintained inventory with ownership, scope alignment, and evidence that it stays current (ISO/IEC 27001 overview).

What’s the difference between “information assets” and “associated assets”?

Information assets are the data and knowledge you need to protect (datasets, code, configs, logs). Associated assets are the systems and services that store/process/transmit that information (applications, devices, cloud services, third parties).

How do we handle SaaS tools and third parties in the inventory?

Record the SaaS application as an associated asset, identify the information types it processes, and link it to your third-party onboarding and due diligence records. If a third party touches regulated or customer data, make that relationship explicit in the inventory record.

How detailed does “location” need to be in cloud environments?

Detailed enough to drive security decisions and incident response. Capture the cloud account/subscription/project and region where data resides, plus the service type (object storage, database, compute) so control owners can validate encryption, access, and logging.

Who should be the asset owner: IT, Security, or the business?

Assign a business owner who can accept risk and fund remediation, and a technical custodian who can implement changes. Put both in the record so accountability stays intact during org changes.

What evidence should we show an auditor to prove the inventory is maintained?

Provide a dated inventory export, samples of workflow-triggered updates (tickets/approvals), and a periodic review or reconciliation record with follow-up remediation items closed out (ISO/IEC 27001 overview).