ISO 27001 Compliance Gap Analysis Template

Your vendor just claimed ISO 27001 compliance. Now you need to verify 93 controls across 4 control categories while mapping them to your SOC 2 Type II requirements. Without a structured template, this assessment becomes a multi-week email chain of evidence requests and control clarifications.

The ISO 27001 gap analysis template solves this by providing a pre-mapped framework that aligns ISO controls with your existing compliance obligations. Each control includes specific evidence requirements, maturity scoring criteria, and cross-framework mapping to SOC 2 Trust Service Criteria, NIST CSF subcategories, and GDPR articles.

This template transforms unstructured vendor assessments into repeatable, defensible evaluations that satisfy both your internal risk committee and external auditors.

Core Template Components

Control Assessment Matrix

The assessment matrix forms the backbone of your gap analysis. Each row represents one of the 93 ISO 27001:2022 controls, structured across four columns:

Column	Purpose	Example Entry
Control Reference	ISO clause number and title	A.8.1 - User endpoint devices
Current State	Vendor's implementation status	"MDM deployed for 80% of devices"
Required Evidence	Specific artifacts needed	MDM policy, device inventory, exception log
Gap Score	Numerical assessment (0-5)	3 - Partially implemented

Evidence Collection Framework

Evidence collection typically consumes the majority of assessment time. The template accelerates this through pre-defined evidence requests:

Information Security Policies (A.5)

• Request: Current information security policy suite
• Format: PDF with version control and approval signatures
• Review focus: Coverage completeness, update frequency, role definitions

Access Control (A.8)

• Request: User access reviews from last 90 days
• Format: Excel export from identity management system
• Review focus: Segregation of duties, privileged access management, termination procedures

Physical Security (A.7)

• Request: Data center audit reports or hosting attestations
• Format: SOC 2 Type II report or equivalent
• Review focus: Environmental controls, visitor logs, asset disposal

Risk Scoring Methodology

Each control receives a maturity score:

• 0 - Not Implemented: Control doesn't exist
• 1 - Ad Hoc: Informal processes, no documentation
• 2 - Developing: Documented but inconsistent application
• 3 - Defined: Standardized processes with regular execution
• 4 - Managed: Measured effectiveness with KPIs
• 5 - Optimized: Continuous improvement with automation

Controls scoring 0-2 require immediate remediation plans. Scores of 3+ meet minimum compliance thresholds.

Industry-Specific Applications

Financial Services Implementation

Financial institutions face additional scrutiny under regulations like PCI DSS and SOX. The template includes supplementary controls for:

Data Encryption (A.8.24)

• PCI DSS Requirement 3.4 alignment
• Encryption key management procedures
• Transmission security protocols

Incident Response (A.5.24-A.5.26)

• 24-hour breach notification requirements
• Customer data impact assessment procedures
• Regulatory reporting workflows

Healthcare Modifications

Healthcare organizations must align ISO 27001 with HIPAA requirements:

Access Management (A.5.15-A.5.18)

• Minimum necessary access principles
• Role-based access control matrices
• Audit logging for PHI access

Business Continuity (A.5.29-A.5.30)

• 72-hour data recovery requirements
• Alternative care site procedures
• Medical device continuity plans

Technology Sector Adaptations

SaaS providers require enhanced focus on:

Development Security (A.8.25-A.8.28)

• Secure coding standards verification
• SAST/DAST testing evidence
• Dependency management processes

Multi-tenancy Controls

• Data segregation architecture
• Cross-tenant access prevention
• Customer data portability procedures

Framework Integration Mapping

SOC 2 Trust Service Criteria Alignment

ISO 27001 Control	SOC 2 Criteria	Evidence Overlap
A.5.1-A.5.8 (Policies)	CC1.4, CC1.5	Policy documentation
A.8.2-A.8.5 (Access)	CC6.1-CC6.3	Access reviews, provisioning logs
A.8.9-A.8.11 (Data)	CC6.6-CC6.7	Classification, retention policies

NIST CSF Crosswalk

The template maps ISO controls to NIST functions:

• Identify: Asset management (A.5.9-A.5.14)
• Protect: Access control (A.8.2-A.8.8)
• Detect: Monitoring (A.8.15-A.8.16)
• Respond: Incident management (A.5.24-A.5.26)
• Recover: Continuity planning (A.5.29-A.5.30)

Implementation Best Practices

Pre-Assessment Preparation

Before sending the template:

1. Customize control requirements based on vendor criticality tier
2. Remove non-applicable controls (document justification)
3. Add contract-specific security requirements
4. Set realistic evidence collection timelines

During Assessment Execution

Effective assessment requires structured communication:

• Schedule weekly evidence review calls
• Use shared repositories for evidence collection
• Document clarification questions in the template
• Track remediation commitments with due dates

Post-Assessment Actions

Gap identification triggers specific workflows:

• Critical Gaps (Score 0-1): Escalate to vendor executive sponsor within 48 hours
• Major Gaps (Score 2): Require remediation plan within 30 days
• Minor Gaps (Score 3): Track in quarterly business reviews

Common Implementation Mistakes

Over-Scoping Assessments

Requesting all 93 controls for every vendor wastes resources. Tier your requirements:

• Tier 1 (Critical): Full ISO 27001 assessment
• Tier 2 (Important): Focus on A.5, A.8, and A.6 families
• Tier 3 (Standard): Limit to 20 core controls

Evidence Without Context

Raw evidence dumps create more work. Require vendors to:

• Map each artifact to specific controls
• Highlight relevant sections
• Provide implementation summaries
• Include coverage percentages

Ignoring Compensating Controls

Vendors may implement alternative controls that achieve the same outcome. Document these variations:

• Automated access reviews replacing manual processes
• Third-party penetration tests substituting for internal assessments
• Cloud-native controls replacing traditional infrastructure security

Frequently Asked Questions

How long should an ISO 27001 gap analysis take with this template?

Initial assessment typically requires 2-3 days for evidence review, plus 5-10 business days for vendor evidence collection. Critical vendors may need additional deep-dive sessions.

Can I use this template if my vendor isn't ISO 27001 certified?

Yes. The template works for both certified and non-certified vendors. Non-certified vendors typically show more gaps but the assessment process remains identical.

Which ISO 27001 version should I assess against?

Use ISO 27001:2022 (published October 2022). Vendors certified under ISO 27001:2022 have until October 2025 to transition, but assess against the current standard.

How do I handle cloud service providers with their own compliance frameworks?

Map their framework (AWS Security Hub, Azure Policy, GCP Security Command Center) to ISO controls. Most major cloud providers publish official mapping documents.

Should I require remediation for all identified gaps?

Focus on controls that directly impact your risk exposure. Document accepted risks for gaps in non-critical areas rather than forcing unnecessary remediation.

How often should I re-assess vendors using this template?

Annual assessments for Tier 1 vendors, biennial for Tier 2, and upon contract renewal for Tier 3. Trigger immediate re-assessment after security incidents.