ISO/IEC 27701:2025: What the New Stand-Alone PIMS Means for Your Privacy Strategy

Privacy obligations are expanding faster than many organisations’ ability to govern them effectively. As regulators increasingly expect demonstrable accountability, not just documented policies, privacy management has become a strategic and board-level concern rather than a purely operational one.

ISO/IEC 27701:2025 matters because it fundamentally reshapes how organisations can approach privacy governance. For the first time, ISO 27701 can operate as a stand-alone management system, without mandatory dependency on ISO/IEC 27001, making structured privacy assurance more accessible and more targeted.

By the end, you will understand the practical implications of the new standard, what has changed and how to respond without creating unnecessary complexity or audit risk.

What is ISO/IEC 27701:2025?

ISO/IEC 27701:2025 is the second edition of the international standard for a Privacy Information Management System (PIMS), defining how organisations establish, implement, maintain, and continually improve structured privacy governance. Published in October 2025, it officially replaces the first edition (ISO/IEC 27701:2019).

The standard specifies requirements for establishing, implementing, maintaining, and continually improving a PIMS, and it provides implementation guidance. It's applicable to all types and sizes of organisations acting as Personally Identifiable Information (PII) controllers or PII processors.

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What Has Changed in ISO/IEC 27701:2025?

The second edition of ISO/IEC 27701:2025 includes a technical revision that introduces a major structural and conceptual change.

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Stand-Alone Management System Standard

The most significant change in ISO/IEC 27701:2025 is its redesign as a fully stand-alone management system standard, positioning privacy governance alongside other established ISO management disciplines rather than as an extension of information security.

• 2019 Edition: The initial edition was an extension to the ISO/IEC 27001 Information Security Management System (ISMS), meaning an organization could not be certified to ISO/IEC 27701 without first establishing and maintaining an ISO/IEC 27001 ISMS.
• 2025 Edition: The new version is a fully independent standard. This means an organisation can now implement and certify a PIMS based on ISO/IEC 27701:2025 without a mandatory pre-existing certification to ISO/IEC 27001, making privacy certification more accessible. The standard still allows for an organisation to align or integrate its PIMS with other management system standards, particularly ISO/IEC 27001.

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Structure and Content Updates

The standard adopts the harmonised ISO management system framework, improving consistency, integration, and auditability across organisational governance structures.

• Normative Requirements: The main body of the document (Clauses 4 through 10) sets the requirements for the PIMS (e.g., Context, Leadership, Planning, Operation, etc.).
• PIMS Controls and Guidance:
  • Annex A (Normative): Provides PIMS reference control objectives and controls specifically for PII controllers and PII processors.
  • Annex B (Normative): Contains implementation guidance for PII controllers and PII processors, corresponding to the controls in Annex A.

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Alignment with International Frameworks

The document includes several informative annexes that provide mapping to key global privacy and security documents, ensuring global relevance:

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These mappings support organisations in translating regulatory and privacy obligations into an auditable, operational management system, rather than treating compliance as a one-off or purely legal exercise.

The revised edition ensures continuity of content while reflecting the evolution of privacy management as a distinct discipline.

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Ready to Update Your Privacy Program?

For organisations already aligned with ISO/IEC 27701:2019, the 2025 revision is not a simple document refresh, it requires a considered reassessment of scope, governance, and how privacy management integrates with existing risk and assurance activities. For organisations new to PIMS, it provides a clearer and more focused starting point.

Don't wait for a data breach or a regulatory fine to bring your organisation into compliance. The shift of ISO/IEC 27701:2025 to a stand-alone standard makes comprehensive privacy management more straightforward than ever before.

Download our complimentary ISO/IEC 27701:2025 Transition and Implementation guide today to understand the detailed steps your organisation must take to migrate from the 2019 edition, or to start your new PIMS implementation journey.

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