Annex A 8.26: Application Security Requirements

Annex a 8.26: application security requirements requirement means you must define security requirements for applications (build, buy, or configure) and prove they are built into the application lifecycle from design through change and retirement. Operationalize it by publishing an application security requirements standard, wiring it into SDLC/CI-CD gates and third-party intake, and retaining evidence that requirements were applied on real releases. ¹

Key takeaways:

• Write measurable application security requirements and map them to each SDLC stage, including third-party and low-code/SaaS configurations.
• Turn requirements into repeatable gates (design review, code review, SAST/DAST, dependency checks, security sign-off) with exceptions handling.
• Keep assessor-ready evidence: requirements standard, traceability to tickets/releases, and recurring metrics and reviews. ¹

Annex A 8.26 sits in the “technological controls” family and is assessed like an engineering control: auditors will ask where your application security requirements live, how teams know what to do, and how you prove the requirements were applied consistently. Treat it as a “requirements-to-evidence” problem, not a policy-writing exercise. ¹

For most service organizations, the tricky part is scope. “Application” includes customer-facing products, internal apps that process sensitive data, integrations and APIs, and configured platforms (CRM, ITSM, data pipelines) where the configuration behaves like code. You also have to cover software you do not write: purchased applications, open-source components, and third-party services embedded into your stack. ¹

This page gives requirement-level implementation guidance you can run with immediately: who owns what, what artifacts to create, which SDLC gates to implement, how to handle exceptions, and what evidence an ISO 27001 auditor typically expects. It also includes a practical 30/60/90 plan and exam questions that commonly stall assessments. ¹

Regulatory text

Control reference: ISO/IEC 27001:2022 Annex A 8.26 (Application Security Requirements). ²

Provided excerpt (summary-level): “ISO/IEC 27001:2022 Annex A control 8.26 implementation expectation (Application Security Requirements).” ¹

Operator meaning (what you must do):

• Define application security requirements that are appropriate to your risks and your environment (build, buy, and configure). ¹
• Embed those requirements into how applications are designed, built/configured, tested, released, and changed so they are consistently applied. ¹
• Keep evidence that requirements exist, are approved, are communicated to teams, and are enforced in day-to-day delivery. ¹

Plain-English interpretation

You need a written, actionable set of security requirements for applications, and you must show they drive engineering behavior. “Actionable” means a developer, product owner, or procurement lead can read the standard and know what must happen before a release or purchase goes live.

A good interpretation for audits: “We have a single source of truth for application security requirements, we apply it to all in-scope applications, and we can trace requirements to real work items and release evidence.” ¹

Who it applies to

Entity scope

• Service organizations seeking ISO/IEC 27001 certification or maintaining alignment with Annex A controls. ¹

Operational scope (what systems/processes)

Apply 8.26 to:

• Custom-developed applications (web, mobile, desktop, services, APIs).
• Configured platforms (SaaS and low-code) where configuration controls data flows, access, business logic, or integrations.
• Purchased software and embedded third-party components (libraries, SDKs, container images, managed services) that become part of your runtime.
• Material changes (new features, auth changes, encryption changes, new integrations, major dependency upgrades).

A practical scoping rule: if an application processes sensitive data or is internet-accessible, it should be explicitly in scope for your application security requirements standard and gates.

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

Step 1: Publish an “Application Security Requirements Standard”

Create a controlled document owned by AppSec/Engineering with Compliance review. Keep it short enough to be used, but specific enough to audit.

Minimum content checklist (make each item testable):

• Data handling requirements: classification mapping, storage/retention expectations, secrets handling.
• Identity and access: authentication standard, session management, authorization model expectations (least privilege, role design).
• Cryptography: when encryption is required in transit/at rest; key management expectations.
• Input/output security: validation, output encoding, file upload controls.
• Logging/monitoring: security event logging expectations (what, where, retention owner).
• Dependency/third-party component rules: approved sources, vulnerability handling, patch expectations.
• Secure configuration baselines: environment hardening, debug modes off, headers, TLS settings.
• Security testing requirements: what tests must run and when (design review, code review, automated scanning, pen test triggers).
• Release criteria: what must be true before production release, and who can grant exceptions.
• Exception process: formal risk acceptance with expiry and compensating controls.

Keep it aligned to your ISMS: link to your risk assessment method and statement of applicability so assessors can see why requirements exist. ¹

Step 2: Build a “requirements-to-SDLC” mapping (traceability)

Create a simple matrix that maps each requirement to:

• SDLC stage (design, build, test, deploy, operate, change)
• Control mechanism (manual review, automated CI check, configuration check)
• Evidence produced (ticket, pipeline output, approval record)

This matrix becomes your audit “control operation” story and prevents gaps like “we have requirements but they aren’t enforced.”

Step 3: Implement enforcement points (gates) that match your delivery model

Pick gates you can prove, not aspirational ones.

Common gate pattern:

• Design gate: threat modeling or security design review required for defined triggers (new auth, new data store, new external integration).
• Build gate: peer code review required; protected branches; signed commits if you use them.
• CI gate: automated checks (SAST, dependency scan, secret scanning) with documented pass/fail criteria and exception handling.
• Pre-release gate: change record includes security checklist; approval by engineering owner; AppSec review for high-risk changes.
• Post-release gate: monitoring enabled; logging verified; vulnerabilities triaged.

For purchased or SaaS applications:

• Add a procurement gate: security requirements become contractual/security review criteria, plus configuration standards and admin access controls.

Step 4: Define ownership and RACI for decisions

Auditors look for accountability:

• Engineering: implements requirements and remediates findings.
• AppSec or Security Engineering: authors requirements, sets testing standards, reviews exceptions.
• Compliance/GRC: confirms control design, monitors evidence cadence, and runs internal checks.
• Product/Business owner: accepts residual risk when exceptions are granted.

Step 5: Create a vulnerability and exception workflow that ties back to requirements

8.26 breaks down when teams treat scanning as “best effort.” Make it deterministic:

• Define severity-based SLAs as internal guidance (avoid publishing numbers as facts).
• Require documented triage decisions (fix, mitigate, accept, false positive) and link them to tickets.
• Timebox exceptions with an expiry date and require compensating controls.

Step 6: Prove it works with recurring evidence capture

Operationalize “recurring evidence capture” as a routine:

• Pull sample releases each month/quarter and collect: pipeline logs, approvals, scan results, and remediation tickets.
• Track “requirements coverage” by application: which apps have CI scanning enabled, which have threat models, which have monitored logs.
• Run a periodic control self-test and record results and corrective actions. ¹

Where Daydream fits naturally: use Daydream to map Annex A 8.26 to your actual SDLC controls and automate recurring evidence collection from Jira/GitHub/GitLab and CI outputs, so your audit package is assembled continuously rather than at audit time.

Required evidence and artifacts to retain

Keep evidence that shows design + operation:

Core documents

• Application Security Requirements Standard (version-controlled, approved).
• SDLC procedure showing where requirements are applied.
• Requirements-to-SDLC mapping matrix.
• Exception/risk acceptance procedure and template.

Operational evidence (sampled across apps/releases)

• Secure design reviews or threat models (where triggered).
• Code review records (PR approvals, branch protection settings).
• CI/CD outputs: SAST/dependency/secret scan results and gating status.
• Pen test reports or targeted assessments when required by your triggers.
• Vulnerability triage tickets and remediation/mitigation evidence.
• Change/release approvals that include security checks.
• Third-party security review records for purchased apps/components that are material to the application.

Governance evidence

• Training/communications proving teams received requirements.
• Metrics or dashboards used to monitor compliance with the requirements.
• Internal audit or control testing results with corrective actions. ¹

Common exam/audit questions and hangups

Assessors commonly push on these points:

1. “Show me the requirements.” If requirements are scattered across wikis and tribal knowledge, you will struggle.
2. “How do you enforce them?” “We expect developers to…” is weak without gates or documented reviews.
3. “What’s your scope?” If you omit SaaS configurations, scripts, or APIs, expect follow-up questions.
4. “How do you handle open source and third-party components?” You need rules plus evidence of scanning/approval.
5. “Show me exceptions.” Auditors often ask for risk acceptances and how you ensure they expire.
6. “Give me a sample.” Be ready to walk through one release end-to-end with artifacts.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Writing a generic policy without testable requirements.
  Fix: Convert statements into “must” requirements tied to evidence (PR approvals, pipeline checks, documented review).
• Mistake: Covering only in-house code.
  Fix: Include bought software, SaaS configuration, and third-party components in your requirements and intake gates.
• Mistake: No traceability from requirements to delivery artifacts.
  Fix: Maintain a mapping matrix and require ticket links in change/release records.
• Mistake: Scanning exists but does not drive decisions.
  Fix: Define pass/fail criteria, triage workflow, and exception approvals with expiry.
• Mistake: One-size-fits-all security reviews that teams bypass.
  Fix: Use triggers (data sensitivity, exposure, auth changes) so reviews are predictable and defensible.
• Mistake: Evidence collected only right before the audit.
  Fix: Set a recurring evidence capture routine; automate collection where possible. ¹

Enforcement context and risk implications

ISO 27001 is a certification standard rather than a regulator, so “enforcement” typically shows up as audit findings: nonconformities, surveillance audit issues, or certification delays. Operationally, weak application security requirements increase the likelihood of vulnerabilities making it to production, inconsistent security across teams, and uncontrolled third-party component risk.

Translate that into business risk language:

• Internet-facing defects become incident drivers.
• Poor requirements create inconsistent engineering practice across teams and acquisitions.
• Missing evidence becomes a governance failure even when engineering work is happening. ¹

A practical 30/60/90-day execution plan

First 30 days (establish the control)

• Name an owner (AppSec/Engineering) and agree scope: which applications, platforms, and pipelines are in.
• Draft and approve the Application Security Requirements Standard.
• Create the requirements-to-SDLC mapping matrix.
• Identify current enforcement points and gaps ².

Days 31–60 (wire into operations)

• Implement minimum gates for highest-risk apps: code review + CI scanning + release checklist.
• Stand up the exception workflow with risk acceptance and expiry.
• Add third-party intake criteria for purchased apps/components that are embedded in your products.
• Start collecting a repeatable evidence packet for a small sample of releases.

Days 61–90 (scale and make it auditable)

• Expand gates across remaining in-scope repos and configured platforms.
• Run a control self-test: pick sample applications and prove requirements were followed end-to-end.
• Build an audit binder: standard, mappings, samples, exceptions, metrics.
• Automate evidence pulls where feasible (Daydream can reduce manual compilation and keep evidence current). ¹

Frequently Asked Questions

Does Annex A 8.26 apply if we don’t develop software?

Yes if you configure SaaS platforms, build workflows, or integrate systems in ways that affect security. Treat “configuration as code” and require security requirements for those changes. ¹

What’s the minimum an auditor will accept as “application security requirements”?

A controlled, approved standard with testable requirements, plus evidence it is applied on real releases. A checklist alone is rarely enough without traceability to engineering artifacts. ¹

How do we handle different stacks and teams without writing a huge standard?

Write baseline requirements that apply everywhere, then add short stack-specific appendices (web, mobile, cloud, data). Keep enforcement consistent through shared CI templates and a common exception process.

Are SAST/DAST required?

The control expects defined security requirements and implementation evidence, not specific tool names. If you use tools, document why, where they run, and how results drive remediation or exceptions. ¹

How do we prove third-party components are covered?

Include component rules in the standard (approved sources, vulnerability handling) and retain evidence such as dependency scan outputs, SBOMs if you generate them, and tickets showing remediation decisions.

What evidence sample is best for the audit?

Pick a recent production release for a high-risk application and show the full chain: requirements, design review trigger decision, PR approvals, CI results, vulnerability triage, and release/change approval.

Footnotes

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

2. ISO/IEC 27001 overview