Annex A 8.4: Access To Source Code

Annex A 8.4 (Access to Source Code) requires you to strictly control, monitor, and justify who can view or change source code, and to prevent unauthorized access or tampering across your development toolchain. To operationalize it fast, define code access rules, enforce them in your repositories and CI/CD, and retain repeatable evidence that access is approved, least-privilege, and reviewed. ¹

Key takeaways:

• Treat source code as a high-value information asset and explicitly scope which repos, branches, and build pipelines are in scope for control 8.4.
• Enforce least-privilege and separation of duties in repo permissions, branch protections, and CI/CD secrets, then prove it with access logs and reviews.
• Make evidence collection recurring and assessor-ready: approvals, access reviews, and technical settings snapshots matter as much as the policy.

Annex a 8.4: access to source code requirement is one of the controls assessors use to test whether your SDLC security is real or just documented. If a developer, contractor, or third party can access sensitive repositories without approval, or if admin rights are granted informally, you have a material integrity and confidentiality gap. Source code access failures also create downstream risk: unauthorized changes, embedded secrets, backdoors, IP loss, and compromised releases.

Operationally, you pass 8.4 by doing two things consistently. First, you implement technical guardrails in the places engineers actually work: Git hosting, identity provider, CI/CD, artifact registries, and secrets management. Second, you can show repeatable evidence that those guardrails are governed: access is requested and approved, periodically reviewed, removed when no longer needed, and logged. ISO 27001 expects an implemented, operating ISMS, so your goal is to make 8.4 a routine control with clear ownership and low friction, not a one-time project. ¹

Regulatory text

Framework excerpt (provided): “ISO/IEC 27001:2022 Annex A control 8.4 implementation expectation (Access To Source Code).”
Control summary: Annex A 8.4: Access To Source Code. ¹

What the operator must do (requirement-level interpretation):

• Define source code as a protected asset class within your ISMS scope, then identify where it lives (repos, mirrors, backups, build systems). ¹
• Restrict access to authorized users based on business need (least privilege) and role, including third-party developers and contractors. ¹
• Implement change controls for code modifications (for example, protected branches and required reviews) and maintain traceability from change request to merged code. ¹
• Monitor and review access, and keep evidence that access is governed and periodically revalidated. ¹

Plain-English interpretation (what assessors look for)

Assessors are trying to answer three questions:

1. Can the wrong person see your code? If yes, confidentiality and IP controls are weak.
2. Can the wrong person change your code? If yes, integrity of production software and releases is at risk.
3. Can you prove control operation without heroics? If you need a one-off data pull to explain permissions, you will struggle in surveillance audits.

Passing evidence usually combines: documented rules (policy/standard), technical enforcement (repo and CI/CD settings), and recurring governance (access reviews, offboarding, logging, exception management). ¹

Who it applies to (entity + operational context)

Entity scope: Any organization implementing ISO/IEC 27001 with software development or configuration code in scope, including service organizations building products, delivering managed services, or operating internal applications. ¹

Operational scope (typical in-scope systems):

• Git hosting (GitHub/GitLab/Bitbucket/Azure Repos)
• Identity provider and SSO/MFA (Okta, Entra ID, etc.)
• CI/CD systems (GitHub Actions, GitLab CI, Jenkins, Azure DevOps)
• Artifact registries (container registries, package registries)
• Secrets management (vaults, CI/CD secrets, KMS)
• Code backups, mirrors, and export processes
• Third-party access paths (MSPs, contractors, outsourced dev teams)

If you have no “software,” you may still have source-like assets: infrastructure-as-code, configuration-as-code, scripts, analytics notebooks, or automation that can alter production behavior. Those should be treated as source code for 8.4 purposes if they can change security posture or service operation. ¹

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

Use this implementation sequence to get to an assessable state quickly.

1) Define “source code” and map repositories

• Create an inventory of code locations: orgs/projects, repos, key branches, CI/CD projects, and where build artifacts are produced.
• Classify repos by sensitivity (public, internal, restricted). Include criteria such as customer-impacting code, cryptographic material, authentication/authorization components, and infrastructure-as-code.

Output: Source Code Inventory (living document) tied to your asset management approach. ²

2) Establish access rules (policy-to-technical translation)

Write a short standard (1–2 pages) that turns intent into enforceable rules:

• Identity: SSO required, MFA required for privileged actions.
• Authorization: role-based access groups; no direct user grants except break-glass.
• Privilege: limit repo admins; define who can approve merges; restrict force pushes.
• Change integrity: branch protection; pull request reviews; status checks; signed commits if you already support it.
• Third-party access: time-bound access, sponsor required, separate accounts, and offboarding triggers.

Output: “Source Code Access Standard” mapped to Annex A 8.4 and your access control program. ¹

3) Enforce controls in the repo platform

Minimum technical baseline most assessors expect to see:

• SSO enforced for org/repo access.
• MFA enforced for all users, and stricter requirements for admins/maintainers.
• Protected default branches with required reviews.
• Required status checks before merge (CI build, tests, SAST if in scope for your program).
• Restrict who can create deploy keys and who can manage webhooks/integrations.
• Disable unused authentication methods where feasible.

Evidence tip: Take screenshots or configuration exports of org/repo settings and retain them on a recurring cadence. ³

4) Control CI/CD and pipeline identities (often the real gap)

Many incidents route through automation rather than humans. For 8.4, treat CI/CD as a privileged actor:

• Use short-lived tokens or workload identity where available.
• Restrict who can edit pipeline definitions.
• Separate duties: developers can propose pipeline changes, but require review/approval by a small set of maintainers.
• Lock down build secrets: limit read access, prevent secrets in logs, rotate on personnel changes.
• Protect artifact publishing permissions (who can push images/packages).

Output: CI/CD Access & Secrets Control Procedure + settings evidence (pipeline permissions, secrets access logs if available). ¹

5) Make access request, approval, and review auditable

Implement three governance motions:

• Joiner/mover/leaver workflow: access granted through ticketed request with manager/system owner approval; access removed on termination and contract end.
• Periodic access review: validate membership in code access groups; confirm repo admin list; confirm third-party access still needed.
• Exception process: document rationale, compensating controls, expiration date, and re-approval requirement.

If you need a system to keep this clean, Daydream can track control ownership, schedule recurring evidence capture, and store assessor-ready artifacts for 8.4 alongside access review attestations. ¹

6) Log, detect, and investigate

8.4 is stronger when you can show monitoring and follow-up:

• Enable audit logging for repo admin actions, permission changes, deploy key creation, and token creation.
• Send logs to your SIEM or centralized logging.
• Define an investigation playbook for suspicious repo access or unusual commits (who triages, what data to collect, escalation path).

Output: Logging configuration evidence + incident response linkage for code-related events. ²

Required evidence and artifacts to retain (assessor-ready checklist)

Keep evidence that proves both design and operation:

Governance

• Source Code Access Standard (approved, versioned)
• Source Code Inventory and repo sensitivity classification
• Access request and approval records (tickets) for a sample of users (employees and third parties)
• Exception register for code access deviations (with expiry and approvals)

Technical configuration

• Repo org settings export or screenshots (SSO/MFA enforcement, base permissions)
• Branch protection rules and PR review requirements for key repos
• CI/CD permissions model documentation (who can modify pipelines, who can release)
• Secrets management settings and access control list snapshots

Operational

• Access review evidence (attestations, reviewer, date, actions taken)
• Offboarding evidence showing removal from code access groups
• Audit log samples (permission changes, admin actions) and retention settings
• Evidence of remediation when issues found (ticket, PR, merged fix)

Common exam/audit questions and hangups

Expect these and prepare the artifacts before you’re asked:

• “Show me who has admin rights to your repos and why.”
• “How do you ensure contractors’ access ends when the engagement ends?”
• “Can a developer push directly to the main branch? Show the setting.”
• “Who can change the CI/CD pipeline that deploys to production?”
• “Do you log permission changes and token creation? Where are the logs retained?”
• “How do you prevent secrets from being committed to source code?”

Hangup pattern: teams document the policy but can’t produce a clean list of repos in scope or demonstrate that branch protections are consistently applied across “important” repositories.

Frequent implementation mistakes (and how to avoid them)

1. Relying on “private repo” as the control. Private does not equal least privilege. Use group-based access and reduce admin sprawl.
2. Ignoring machine identities. Deploy keys, CI tokens, and service accounts often have broad permissions. Inventory and constrain them.
3. No defined repo owner. Every repo should have an accountable owner for access approvals and reviews.
4. Third-party access without sponsorship. Require an internal sponsor and time-bound access; review third-party accounts explicitly.
5. One-off evidence scrambles. Build recurring evidence capture into your GRC workflow. If you can’t reproduce evidence on demand, it will fail under surveillance cadence. ²

Risk implications (why 8.4 is “medium” severity but high blast radius)

Annex A 8.4 is often rated medium in catalogs because it is a control topic, not a direct legal obligation with statutory penalties in the standard itself. Operationally, weak source code access can become a high-impact incident if it enables unauthorized production changes, supply chain compromise through CI/CD, or exposure of proprietary code. Tie the control to your risk register: integrity of releases, customer trust, and contractual security commitments commonly depend on provable code governance. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize and define)

• Identify in-scope code systems and generate a Source Code Inventory.
• Publish the Source Code Access Standard with clear roles: repo owner, approver, admin, CI/CD maintainer.
• Turn on SSO and MFA enforcement for code platforms where feasible.
• Enable audit logging and confirm retention is configured.

By 60 days (enforce and govern)

• Implement baseline repo controls: branch protection, required reviews, restricted admin permissions.
• Bring CI/CD under control: restrict who can edit pipelines, review secrets access, constrain tokens.
• Roll out a ticketed access request path for code access and admin elevation.
• Run your first access review for code access groups and repo admins; remediate findings.

By 90 days (prove repeatable operation)

• Normalize evidence capture: monthly or quarterly exports of settings, access review attestations, and exception tracking.
• Add detection and response: alerts for permission changes and token creation, plus a documented triage path.
• Test offboarding: verify access removal for recent leavers and contractors; document results.
• Prepare an assessor pack: policy, inventory, samples of approvals, review results, and technical settings evidence.

Daydream fits best once your baseline is in place and you need control mapping, scheduled evidence collection, and clean auditor exports for Annex A 8.4 across multiple engineering systems. ¹

Frequently Asked Questions

Does Annex A 8.4 apply to open-source repositories?

Yes, if the repo is in scope for your ISMS and changes can impact your service or customers. The control focus shifts to preventing unauthorized changes (integrity) rather than secrecy for public code. ²

What counts as “source code” for 8.4 if we are mostly SaaS and configuration-driven?

Include infrastructure-as-code, deployment scripts, policy-as-code, and automation that can change production behavior. Treat any code-like asset that can affect security or availability as in scope. ³

Do we need a separate policy just for source code access?

You can satisfy 8.4 with an access control policy plus a short standard that translates requirements into repo and CI/CD settings. Assessors usually need a clear bridge between policy intent and technical enforcement. ²

How should we handle emergency access or break-glass repo admin rights?

Define a break-glass process with named custodians, strong authentication, logging, and post-event review. Record each use as an exception or incident record with remediation actions. ²

What evidence is strongest for audits: screenshots or system exports?

Prefer exports or API-based configuration snapshots where your platform supports it, then supplement with screenshots for settings that are hard to export. The key is repeatability and clear timestamps. ³

Our engineers share service accounts for CI. Will that fail 8.4?

Shared credentials create attribution and access control gaps. Move toward unique identities for admins and controlled, auditable machine identities for automation, with constrained permissions and rotation. ²

Footnotes

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

2. ISO/IEC 27001 overview

3. ISMS.online Annex A control index