Annex A 8.30: Outsourced Development

Annex a 8.30: outsourced development requirement means you must govern third-party software development as if it were performed internally: set security requirements, embed them into contracts and delivery workflows, and verify the supplier’s secure development practices and outputs through evidence. Operationalize it by integrating third-party due diligence, secure SDLC controls, and acceptance gates into your procurement-to-release process.

Key takeaways:

• Treat outsourced development as part of your secure SDLC, with defined controls and release gates.
• Put security requirements into statements of work and contracts, then test for compliance with deliverables and evidence.
• Keep assessor-ready artifacts: third-party risk records, security requirements, review results, and acceptance evidence.

Outsourced development expands your software supply chain. You may be using a systems integrator to build features, an agency to develop a customer portal, contractors to write mobile code, or a third party to maintain legacy components. Annex A 8.30 exists because these arrangements can bypass internal engineering guardrails if they are treated “like a purchase” rather than “like development.” The control expectation is straightforward: define how outsourced development must be secured, enforce those expectations contractually, and verify the supplier’s work before you ship it.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to anchor Annex A 8.30 to a small number of operational choke points you already control: intake (procurement and onboarding), build (secure SDLC requirements and working practices), and release (acceptance criteria and evidence). Your goal is not to micromanage engineers or suppliers; it’s to ensure outsourced code is developed, reviewed, tested, and delivered under security controls that match your risk appetite and information security management system (ISMS). ¹

Regulatory text

Framework reference: ISO/IEC 27001:2022 Annex A control 8.30 (Outsourced Development). ¹

Provided excerpt (summary-level): “ISO/IEC 27001:2022 Annex A control 8.30 implementation expectation (Outsourced Development).” ¹

What the operator must do (requirement-level): You must ensure outsourced software development activities are subject to appropriate information security controls. In practice, that means:

1. defining security requirements for outsourced development work,
2. embedding those requirements into third-party contracting and delivery processes, and
3. verifying that the supplier’s development practices and delivered software meet those requirements through repeatable evidence. ¹

Plain-English interpretation (what Annex A 8.30 really expects)

If a third party writes or modifies code for you, you still own the risk. Annex A 8.30 expects you to manage outsourced development so it does not become an unmanaged path into your production environment, customer data, or intellectual property. “Manage” here is not a policy-only exercise; it requires demonstrable controls across requirements, contracting, engineering workflow integration, and acceptance testing.

Think in three questions an auditor will implicitly ask:

• Did you tell the supplier what “secure” means for this engagement?
• Did the supplier actually follow secure practices while building?
• Did you verify the deliverable before deploying or accepting it?

Who it applies to

Entity scope

• Any organization implementing ISO/IEC 27001 with software development performed by third parties (common for service organizations). ²

Operational scope (what counts as “outsourced development”)

Include outsourced work where a third party:

• builds new applications, APIs, integrations, or infrastructure-as-code
• maintains or patches existing codebases
• develops mobile apps, web front ends, or internal tools
• performs “staff augmentation” where contractors commit code to your repos
• provides managed development services for product features

Exclude pure COTS procurement where you are only licensing finished software and not directing development, but note the boundary can blur with custom configurations, plugins, or bespoke integrations. Treat those as in-scope if they introduce code you run or code that touches your data.

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

Step 1: Inventory outsourced development relationships (and classify them)

Create or extend your third-party inventory to tag relationships that involve code creation or modification. Capture:

• supplier name and engagement owner
• systems/data touched (including environments)
• delivery model (supplier-hosted, your repos, your CI/CD, their CI/CD)
• release pathway (who can deploy, who approves)

Output: “Outsourced Development Register” (can be a filtered view of your third-party register).

Step 2: Define minimum security requirements for outsourced development

Write a short standard (“Outsourced Development Security Requirements”) that is easy to attach to SOWs. Cover:

• secure coding expectations (language/framework-specific where relevant)
• code review expectations and who performs them
• vulnerability and dependency management expectations
• secrets handling (no secrets in code, use approved vault mechanisms)
• environment segregation and access controls
• logging requirements for security-relevant events (where applicable)
• incident reporting expectations tied to development compromise
• deliverables: SBOM (if you require it), test results, scan outputs, attestation

Avoid generic language that you cannot verify. If you cannot test it or collect evidence for it, rewrite it.

Step 3: Embed requirements into procurement, SOWs, and contracts

Operationalize Annex A 8.30 by making security non-optional at intake:

• Add a procurement checklist item: “Is this outsourced development?” If yes, require InfoSec/GRC review.
• Attach the Outsourced Development Security Requirements to the SOW.
• Contract clauses to include (tailor to your template):
  • right to assess / request evidence relevant to secure development
  • security incident notification tied to code repositories, build systems, and developer endpoints used for your work
  • restrictions on subcontracting and offshore development (or disclosure/approval requirements)
  • IP ownership and code escrow expectations (if relevant)
  • access control requirements for your systems and repositories

Practical tip: If Legal resists “audit rights,” ask for “evidence-on-request” focused on secure SDLC artifacts (scan results, review logs, change control records). This often moves faster.

Step 4: Integrate the supplier into your secure SDLC (don’t create a parallel process)

Pick the model that matches how development is done:

Model A: Supplier commits to your repositories

• Require corporate SSO + MFA for supplier accounts.
• Enforce branch protections, required reviewers, and CI checks.
• Require pull request templates that include security considerations.
• Make SAST/secret scanning mandatory checks before merge.

Model B: Supplier delivers code drops

• Define a controlled intake process: where code is delivered, who can access it, and how it is scanned.
• Run internal scanning (SAST, dependency scanning, malware scanning if you accept binaries).
• Require remediation before acceptance.

Model C: Supplier hosts and operates

• Treat as a broader third-party service, but keep Annex A 8.30 requirements for their SDLC plus deployment controls.
• Require evidence that their release process includes security testing and approvals.

Step 5: Set acceptance criteria and release gates

Define “no-ship” conditions for outsourced deliverables. Common release gates:

• security review completed for material changes
• vulnerabilities triaged and remediated or risk-accepted by the right owner
• code review completed per your standard
• secrets scanning clean or exceptions documented
• test evidence retained and traceable to the release

Tie gates to your change management process so the evidence naturally accumulates.

Step 6: Verify periodically, not just at onboarding

Annex A 8.30 is not a one-time supplier assessment. Establish recurring checks triggered by:

• major releases
• scope expansions (new data types, new environments)
• material security incidents
• subcontractor changes

If you use Daydream to manage third-party risk and control evidence, map Annex A 8.30 to a recurring evidence task set (for example: per-release evidence for high-risk engagements and periodic sampling for lower-risk ones). The objective is simple: predictable collection, consistent retention, and fast assessor response.

Required evidence and artifacts to retain (assessor-ready)

Keep artifacts that prove design and operation:

Governance and scoping

• Outsourced Development Register (filtered third-party inventory)
• data flow / architecture diagrams for the outsourced component (as applicable)
• risk assessment or engagement security review record

Contracting

• executed MSA/SOW with outsourced development security requirements attached
• records of any approved exceptions (and who approved)

Build and delivery evidence

• access provisioning records for supplier developers (and removals at offboarding)
• repository settings evidence (branch protection, required reviews, CI checks)
• code review logs / pull request approvals for sampled changes
• scan outputs (SAST, dependency, secrets) tied to builds/releases
• release/acceptance checklist showing gates passed
• vulnerability triage notes and risk acceptances (if any)

Ongoing oversight

• periodic supplier performance/security check-ins (minutes or tickets)
• incident communications if a development environment compromise occurs

Common exam/audit questions and hangups

Auditors and certification bodies tend to focus on proof that outsourced work is controlled, not assumed.

Common questions

• “Show me a list of outsourced development engagements and the systems they affect.”
• “Where are the security requirements defined, and how do you enforce them contractually?”
• “Provide evidence for one outsourced release: reviews, scans, approvals, and remediation.”
• “How do you control third-party developer access to your repos and CI/CD?”
• “How do you handle exceptions when deadlines collide with security findings?”

Hangups

• No single owner for outsourced development governance (Procurement, Engineering, and Security each think the other owns it).
• Evidence exists in tools but is not retained in a way that’s retrievable for an audit sample.
• Contractors are treated as “internal,” bypassing third-party controls, while still operating outside HR onboarding/offboarding rigor.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Contract-only compliance. You have clauses, but no operational gates.
   Avoid: Make CI checks and release acceptance criteria mandatory for outsourced code paths.

2. Mistake: One-size due diligence. You send a generic questionnaire, then stop.
   Avoid: Tie verification to delivery: require scan results and review evidence for actual releases.

3. Mistake: Shared accounts for supplier developers.
   Avoid: Enforce individual identities with SSO and MFA; make offboarding part of the engagement closeout.

4. Mistake: Accepting binaries with no provenance.
   Avoid: Require source, build instructions, and scanning; if you accept binaries, define malware scanning and integrity controls.

5. Mistake: Exceptions with no expiry.
   Avoid: Document compensating controls, approvers, and a review trigger tied to the next release or scope change.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions. Practically, Annex A 8.30 maps to common failure modes that turn into real incidents: insecure code introduced by third parties, compromised developer credentials, dependency tampering, and unreviewed changes moving into production. The business impact shows up as incident response cost, customer trust loss, and certification risk if you cannot produce evidence that outsourced development is governed. ²

Practical execution plan (30/60/90)

Use phases rather than calendar promises. Treat these as “first,” “next,” and “then” milestones.

First phase: Stabilize (immediate)

• Identify all third parties doing development or code modification.
• Pick one standard: Outsourced Development Security Requirements (short, attachable to SOWs).
• Add a procurement intake question and route outsourced development to Security/GRC review.
• Define minimum evidence to collect for each outsourced release (review + scans + acceptance checklist).

Second phase: Implement (near-term)

• Update contract templates or SOW addenda to include the requirements and evidence-on-request language.
• Align Engineering on the delivery model patterns (repo-based vs code-drop vs supplier-hosted) and define controls for each.
• Implement required CI checks and branch protection for repos that accept outsourced commits.
• Build an audit-ready evidence pack template and run a mock sample on one outsourced release.

Third phase: Operationalize (ongoing)

• Set a recurring oversight cadence for high-risk outsourced development relationships.
• Sample releases to confirm evidence quality and consistency.
• Track exceptions and confirm closure.
• In Daydream, map Annex A 8.30 to a control record with recurring evidence requests so the process survives staff turnover.

Frequently Asked Questions

Does Annex A 8.30 apply if we only use contractors (staff augmentation)?

Yes, if those contractors perform development that affects your systems or data. Treat them as third parties in scope and enforce the same SDLC controls, access governance, and evidence retention.

What’s the minimum evidence an auditor will accept for outsourced development?

Expect to show security requirements, contractual linkage (SOW/clauses), and a sampled release packet with code review and scan/acceptance evidence. If you cannot produce a complete sample quickly, the control will feel ineffective in practice.

We can’t get “audit rights” into the contract. Are we blocked?

You can often meet the intent with “evidence-on-request” language focused on secure development artifacts and incident notification. Pair that with internal verification gates (your scans and reviews) before accepting deliverables.

How do we handle a supplier that won’t share scan results or SDLC details?

Treat it as a risk decision. Reduce exposure by moving scanning and review inside your environment, narrowing access, and tightening acceptance criteria; if the supplier hosts and won’t provide evidence, escalate as a third-party risk exception.

Does this control require an SBOM?

The provided source excerpt does not mandate specific artifacts like an SBOM. If you choose to require an SBOM, document it as your organization’s outsourced development requirement and make it testable.

How do we scope outsourced development for a product that mixes internal and external teams?

Scope by code path and release pipeline: any component or repository where a third party can introduce changes is in scope. Define control points (access, reviews, scans, approvals) at the shared pipeline level so the same guardrails apply to everyone.

Footnotes

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

2. ISO/IEC 27001 overview