Annex A 5.22: Monitoring, Review and Change Management of Supplier Services

To meet the annex a 5.22: monitoring, review and change management of supplier services requirement, you must run an operating process that continuously monitors supplier performance and security, performs periodic reviews against contractual requirements, and controls supplier-driven changes through documented change management. Auditors will look for proof that you detect issues early, reassess risk after changes, and enforce contract terms.

Key takeaways:

• Treat supplier monitoring as an operating control with defined cadence, owners, triggers, and evidence.
• Bind monitoring and review to contracts: SLAs, security requirements, right-to-audit, incident notice, and change notification.
• Implement change triggers so supplier changes automatically force risk review and approvals before impact.

Annex A 5.22 is where many ISO 27001 programs fail in practice: teams do the upfront due diligence, sign the contract, and then “set and forget” the supplier relationship. This control expects ongoing governance. You need a repeatable way to monitor supplier services, review them against agreed requirements, and manage changes that could affect confidentiality, integrity, or availability.

This requirement matters most for critical supplier services: cloud hosting, SaaS handling regulated data, managed security providers, payroll/HR platforms, payment processors, and any outsourced operational process that would materially disrupt your business if it failed. The operational goal is simple: you should be able to show, on demand, what you monitored, what you found, what you did about it, and how you evaluated changes before they created new risk.

ISO 27001 does not prescribe a single tooling approach. A spreadsheet-based program can pass if it is disciplined and evidence-backed, and an expensive platform can fail if it is not run. If you use Daydream, the win is centralized tasking, automated evidence capture, and a clean audit trail tied to each third party, review cycle, and change trigger.

Requirement: Annex A 5.22 monitoring, review, and change management of supplier services

Control intent: Keep supplier services within agreed security and performance boundaries over time, and reassess risk when the supplier or service changes.

This is an operational control, not a one-time assessment. Your program has to show:

• Monitoring: You track supplier service delivery and security signals that matter for your risk.
• Review: You periodically evaluate the supplier against contractual and risk requirements.
• Change management: You control changes that could alter risk, including supplier-initiated changes and your own changes to how you use the supplier.

Regulatory text

ISO/IEC 27001:2022 Annex A control 5.22 implementation expectation (Monitoring, Review and Change Management of Supplier Services). ¹

Operator interpretation (what the assessor expects you to be able to demonstrate):

• You defined what “good” looks like for each relevant supplier service (SLAs, security obligations, compliance obligations).
• You defined how you will monitor those obligations (metrics, reports, alerts, meetings).
• You defined how often you will review the supplier relationship and what artifacts prove the review happened.
• You defined what counts as a change and how change triggers flow into risk review, approvals, and contract updates.
• You can show corrective actions when monitoring/review identifies gaps.

Plain-English interpretation

If a third party provides a service that affects your information security, you must watch it while it runs, re-check it periodically, and re-approve it when something changes. “Watch it” includes security and operational performance. “Re-check it” includes validating they still meet contractual commitments. “Something changes” includes scope, data types, architecture, subprocessors, control environment, locations, or incident patterns.

Who it applies to (entity and operational context)

Applies to any organization running an ISO 27001 ISMS that relies on suppliers/third parties for services that can affect information security. In practice, prioritize:

• Critical suppliers: outage or failure causes material business disruption.
• High-risk suppliers: handle sensitive data, privileged access, or core infrastructure.
• Regulated processing suppliers: process personal, financial, health, or customer confidential data.
• Chain suppliers: suppliers with subprocessors or fourth parties that expand your risk surface.

Operationally, this touches:

• Procurement / Vendor Management / TPRM
• Security / GRC
• IT Ops / SRE (availability and performance signals)
• Legal (contract enforcement and amendments)
• Business owners (service owners accountable for outcomes)

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

1) Build a supplier service inventory tied to risk

Minimum fields to operationalize 5.22:

• Supplier name, service name, business owner
• Data classification handled (if any), access level, integration points
• Criticality tier (critical/high/medium/low)
• Contract identifiers, renewal dates, termination rights
• Subprocessor/fourth-party dependency notes
• Required monitoring and review cadence by tier

Practical rule: if you cannot answer “what should we monitor for this supplier?” you do not yet have a 5.22-ready inventory.

2) Define monitoring requirements per supplier tier

Create a monitoring standard that maps tier → monitoring expectations. Example structure:

Tier	What to monitor	Monitoring sources	Triggers
Critical	uptime, incident notifications, security advisories, subprocessor changes, SLA breaches	status pages, monthly service reports, ticket metrics, SOC report updates, supplier notices	breach, incident, major change, renewal
High	security notices, incident notifications, access changes, key control attestations	supplier portal, quarterly meetings, audit reports	incident, scope change, new data type
Medium/Low	basic performance and contract compliance	annual check-in, renewal review	renewal, significant integration change

Make monitoring actionable: assign owners, define where signals land (ticketing/GRC tool), and define response SLAs for internal triage.

3) Implement a periodic supplier service review workflow

A review is more than “we met with the supplier.” Build a checklist that validates:

• Contractual requirements still match current use (scope, data, access).
• Security assurances are current (attestations, reported incidents, open risks).
• Performance against SLAs and support responsiveness.
• Open issues, remediation plans, and deadlines.
• Subprocessor/fourth-party changes and impact assessment.
• Exit readiness (data return/destruction, migration plan for critical suppliers).

Tip from audits: reviewers will ask for evidence that the review produced decisions. Add explicit outcomes: “continue,” “continue with remediation,” “restrict scope,” “replace,” or “terminate.”

4) Put supplier changes into your change management system

You need defined “change events” that force reassessment. Common triggers:

• Supplier notifies of material security incident.
• Supplier changes hosting region, subprocessors, encryption model, or access model.
• You expand scope: new data type, new integration, new business unit, new privileged access.
• Contract changes: SLA relaxation, shortened breach notice, removal of audit rights.
• Supplier control posture change: SOC opinion changes, report gaps, repeated exceptions.

Operationalize triggers by creating intake paths:

• Contract/legal intake: legal flags changes in terms and routes to GRC.
• IT intake: new integration requests require supplier reassessment.
• Supplier notice intake: mailbox or portal notices create a ticket automatically.
• Renewal intake: renewal calendar triggers review and risk refresh.

5) Tie monitoring findings to remediation and enforcement

When monitoring shows an issue:

• Log it as a supplier risk/issue with severity and owner.
• Require a corrective action plan from the supplier when appropriate.
• Track due dates and evidence of remediation.
• Apply contract levers if needed (service credits, escalation, right to audit, termination for cause).

This is where programs often go soft. A documented escalation path is your proof that monitoring has teeth.

6) Make evidence capture routine (not heroic)

Treat evidence as a byproduct of work:

• Meeting minutes stored in a supplier record.
• SLA reports attached to the monthly/quarterly monitoring task.
• Change tickets linked to supplier record and risk decision.
• Exceptions documented with risk acceptance and expiry.

Daydream fits naturally here by standardizing tasks per tier, collecting artifacts into the supplier record, and keeping a timestamped audit trail of reviews and approvals.

Required evidence and artifacts to retain

Auditors typically accept a mix of policy, procedures, and operating records. Retain:

• Supplier monitoring and review procedure (tiering, cadence, triggers, escalation)
• Supplier inventory with tiering rationale and service owners
• Contract clauses or summaries: SLAs, security requirements, incident notice, change notification, audit rights
• Monitoring records: SLA dashboards/reports, status/outage history, security advisories tracked, support ticket metrics
• Review records: completed review checklists, meeting minutes, decision outcomes, follow-up actions
• Change management records: change requests, impact assessments, approvals, testing/validation evidence where relevant
• Issue and remediation tracking: corrective action plans, closure evidence, risk acceptances with expiry

Common exam/audit questions and hangups

Expect questions like:

• “Show me how you monitor your top critical suppliers. Where are the last monitoring results?”
• “What triggers a supplier reassessment, and show an example where it happened.”
• “How do you know the contract still matches current use of the service?”
• “How do you track supplier incidents and verify remediation?”
• “Who owns the supplier relationship, and who approves risk decisions after changes?”

Hangups that drive nonconformities:

• Reviews happen, but outcomes are not documented.
• Monitoring exists for uptime only; security signals are ignored.
• Supplier changes are learned informally and never recorded.
• Subprocessors are not tracked, so downstream changes bypass review.
• Evidence is scattered across email and cannot be produced on request.

Frequent implementation mistakes and how to avoid them

1. Mistake: One-size-fits-all cadence.
   Fix: tier suppliers and set monitoring/review expectations per tier. Document why.

2. Mistake: Confusing due diligence with monitoring.
   Fix: separate onboarding artifacts (initial risk review) from ongoing operating evidence (monthly/quarterly monitoring, periodic reviews).

3. Mistake: No defined “change trigger.”
   Fix: publish a trigger list and wire it into procurement, IT intake, and legal contract workflows.

4. Mistake: “Review” equals a meeting.
   Fix: require a completed checklist plus a decision and tracked actions.

5. Mistake: No enforcement path.
   Fix: define escalation steps, include legal/procurement actions, and track remediation to closure.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this control. Practically, weak supplier monitoring increases the chance that a supplier incident becomes your incident, and that auditors conclude your ISMS controls are not operating effectively. The risk is operational (outages), security (breaches), and compliance (missed contractual/regulatory obligations passed through suppliers).

Practical 30/60/90-day execution plan

First 30 days (Immediate stabilization)

• Identify your critical and high-risk suppliers, assign service owners, and confirm contract locations.
• Publish a monitoring/review standard: tiers, cadence, triggers, minimum evidence.
• Stand up intake channels for change triggers (renewals, new integrations, supplier notices).
• Start capturing monitoring evidence for the most critical suppliers first.

By 60 days (Operationalize and prove operation)

• Run your first formal reviews for critical suppliers using a consistent checklist.
• Implement issue tracking and escalation for SLA breaches and security findings.
• Align legal/procurement: ensure change notification and incident notice clauses are present for new contracts and renewals.
• Centralize evidence storage per supplier record (Daydream or your existing GRC repository).

By 90 days (Harden and scale)

• Expand reviews and monitoring to high-risk suppliers and key fourth-party dependencies.
• Test change triggers end-to-end: simulate a subprocessor change notice and show the reassessment workflow.
• Add management reporting: overdue reviews, open supplier issues, and change events by tier.
• Prepare an audit packet template per critical supplier (inventory entry, last review, last monitoring record, open actions).

Frequently Asked Questions

What counts as “monitoring” for Annex A 5.22?

Monitoring is any defined activity that checks supplier service delivery and security signals during operations, such as SLA tracking, incident notices, security advisories, and periodic metrics reviews. It must produce records you can show to an auditor.

How do I decide which suppliers need deeper reviews?

Base it on criticality and risk: data sensitivity, privileged access, operational dependency, and regulatory impact. Document the tiering logic and apply different monitoring and review expectations by tier.

Do we need a new change management process just for suppliers?

No. You need supplier change triggers integrated into your existing change management and intake workflows. The key is that supplier-driven changes force a documented risk review and approval.

What evidence is most persuasive in an ISO 27001 audit?

A clean supplier record that includes the monitoring cadence, the most recent monitoring outputs, a completed periodic review with a decision, and any change tickets tied to reassessments. Scattered emails without a repeatable workflow tend to fail.

How should we handle supplier refusals to provide audit reports or security attestations?

Document the request and refusal, assess the risk, and apply compensating controls or contractual escalation. If the supplier is high-risk or critical, this often becomes a business decision with formal risk acceptance or a replacement plan.

Can Daydream help with Annex A 5.22 operation?

Yes, if you configure it to assign supplier owners, schedule monitoring and review tasks by tier, and store evidence and approvals in the supplier record. The value is the audit trail and consistent execution across many third parties.

Footnotes

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