Every organization experiences disruptions. Systems go down, vendors have outages, and people are unavailable when you need them. 

While ISO 27001 doesn’t expect you to eliminate these risks entirely, it does expect you to think through how your business will continue operating. How will your information security management system (ISMS) be maintained when disruptions do occur?

For organizations pursuing ISO 27001 certification, the business continuity policy is one of the clearest signals to auditors that your ISMS is grounded in reality. It shows that you understand your risks and dependencies, that you’ve planned for things not going according to plan, and that you can protect sensitive information even under pressure.

In this guide, we’ll walk through what an ISO 27001 business continuity policy actually is, which requirements matter under ISO 27001:2022, and how to write a policy that stands up under a real audit.

What ISO 27001 auditors actually expect to see

One of the biggest misconceptions about business continuity is that ISO 27001 auditors expect a flawless, enterprise-grade program. In practice, they’re far more interested in whether your approach is reasonable, documented, used in practice, and maintained.

Across hundreds of audits, the same signals consistently matter most to auditors:

• Clear ownership. Someone should be accountable for maintaining continuity documentation, coordinating exercises, and tracking improvements.
• Scope that reflects reality. If you are a remote-first, cloud-native organization, your continuity approach should reflect that. A boilerplate policy written for a traditional on-prem environment raises more questions than it answers.
• Evidence that plans are tested. This does not mean full-scale disaster simulations. Tabletop exercises covering scenarios like cyberattacks, power outages, supply chain disruptions, or natural disasters are often sufficient, especially for smaller organizations, as long as they are documented and result in follow-up actions.
• Assurance that security controls remain in place during disruptions. Annex A 5.29 is especially relevant here, since it addresses emergency access, secure data handling, and the cleanup of any temporary changes made during an incident.
• Continuous improvement. After a test or real incident, you should be able to show what you learned and what changed as a result.

How to write an ISO 27001-compliant business continuity policy + examples

A good business continuity policy does not try to solve every possible disruption. Its job is to set clear expectations for how continuity is handled, who is responsible, and how the organization stays prepared over time. When written well, it acts as a stable anchor for your business continuity plans, incident management processes, and disaster recovery procedures.

The structure below works well in real ISO 27001 audits because it is easy to follow, easy to maintain, and clearly connected to the rest of the ISMS. It also scales. You can start simple and add depth as your organization grows.

1. Document control

Start with the basics: document owner, version number, approval, and review cadence.

This may seem administrative, but it is one of the most common audit pitfalls. We regularly see otherwise solid continuity programs questioned simply because no one can confidently say which version of the policy is current or when it was last reviewed. Clear version control signals that the policy is actively managed and maintained.

Example: “This Business Continuity Policy is owned by the Security & Compliance team. It is reviewed at least annually, or following significant changes to business operations, systems, or risk profile. Updates are versioned, approved by executive management, and communicated to relevant stakeholders.”

2. Purpose

The purpose statement should explain in plain language what the policy does and why that matters.

For example, “This policy defines how the organization prepares for and responds to disruptive events in order to maintain critical business operations, protect customer data, and ensure the ongoing availability of information systems.”

A short, clear purpose statement helps auditors and internal stakeholders quickly understand how business continuity fits into your overall risk management and cybersecurity practices.

3. Scope

Next, define who and what the policy applies to. In most organizations, this includes:

• Employees and contractors
• Information systems and services
• Remote work environments
• Critical third-party providers

Auditors are less concerned with exhaustive lists and more interested in how you determine what’s in scope, what counts as a critical dependency, and where those details are documented. For example, “This policy applies to all employees and contractors, as well as the systems and services used to deliver and support the organization’s SaaS platform. This includes cloud infrastructure, internal tooling, customer-facing applications, and critical third-party service providers.”

4. Roles and responsibilities

This section turns business continuity from an abstract concept into an operational process. It should clearly define who is responsible for:

• Sponsoring the continuity program and providing resources
• Maintaining the policy and related documentation
• Owning system-level recovery procedures
• Ensuring information security is upheld during disruptions

When roles are clear, it becomes much easier to demonstrate accountability during audits and during real incidents.

Here’s example policy language: “Executive management provides oversight and ensures appropriate resources are allocated to the business continuity program. The Security & Compliance team owns this policy and coordinates business continuity and incident response testing. Engineering and IT system owners are responsible for maintaining recovery procedures for the systems they manage. Security leadership ensures information security controls remain effective during disruptive events.”

5. Business impact and continuity requirements

Your policy should explain how your organization identifies critical business activities and defines continuity requirements for each one. This is often done through a business impact analysis (BIA) or a similar prioritization process.

For smaller organizations, this does not need to be overly complex. Starting with the services that directly affect customers, revenue, or security operations is often sufficient.

Within your policy, this can look something like: “The organization identifies critical business activities and supporting systems through a documented business impact analysis. Continuity requirements, including recovery expectations for customer-facing services and supporting infrastructure, are reviewed at least annually and following significant changes to systems or business operations.”

6. Continuity planning and response

This section should explain how the policy connects to your supporting plans without simply duplicating them. The policy sets expectations; the plans provide the step-by-step detail. Common references include:

• The business continuity plan
• Crisis communication procedures
• Incident response and escalation processes
• Disaster recovery procedures

The policy should also clarify how a disruption is declared and who has the authority to activate continuity plans. This helps avoid confusion when quick decisions are required.

An example of this policy language could be, “Documented business continuity, incident response, and disaster recovery plans define activation criteria, escalation paths, and response procedures. Authorized members of the Security & Compliance or Engineering leadership teams may declare a disruptive event and activate continuity plans as needed.”

7. Maintaining information security during disruptions

This is where you address Annex A 5.29 directly.

Your policy should make it clear that security controls remain in place even when normal operations are disrupted. This typically includes principles such as:

• Emergency access being approved, logged, and then revoked
• Sensitive data handling requirements continuing to apply
• Temporary changes or workarounds being reviewed once the incident is resolved

The goal is to show that continuity and information security are aligned, even during incidents. For example, “During disruptive events, the organization maintains appropriate information security controls. Emergency access to production systems is approved and logged, sensitive data handling requirements continue to apply, and any temporary changes or workarounds are reviewed and remediated once normal operations resume.”

8. ICT readiness

To address Annex A 5.30, your policy should state that the technology supporting critical operations is planned, maintained, and tested based on your business continuity needs.

This section does not need to document technical implementation details, but it should establish expectations and point to where those details are maintained. You can reference data backups, recovery strategies, redundancy, or failover capabilities here.

An example policy might state, “ICT readiness measures are planned, implemented, tested, and reviewed to support business continuity objectives. This includes cloud infrastructure hosted in AWS, identity and access management services, and supporting monitoring and alerting systems. Detailed recovery procedures are documented and maintained by system owners.”

9. Testing, review, and improvement

Finally, explain how continuity practices are tested and improved over time. This section often makes or breaks audit outcomes. Even simple tabletop exercises, when documented and followed up on, demonstrate an active program.

For example, “Business continuity and incident response procedures are tested through tabletop exercises at least every six months. Exercise outcomes and improvement actions are documented in a centralized tracking file, owners are assigned, and remediation items are tracked to completion. Lessons learned are incorporated into updated policies and plans.”

Best practices for tech startups, AI companies, and small businesses

We’ve helped thousands of organizations prepare for successful ISO 27001 audits, in addition to maintaining our own certification. Across those engagements, we’ve seen common challenges come up, especially for teams going through certification for the first time.

Most teams struggle because ISO 27001 leaves a lot of room for interpretation. When you’re building everything manually, it’s hard to know what’s “good enough” versus what’s overkill.

One of the most common mistakes we see is treating the first version of the business continuity policy as something that has to be perfect. Teams spend weeks debating edge cases or writing policies that are far more complex than their current environment requires. The organizations that move fastest tend to start with a clear, reasonable baseline, test it early, and improve it incrementally as they learn more about their real risks.

Another frequent issue is a disconnect between stated recovery objectives and actual capabilities. It’s easy to write aggressive recovery targets on paper, but auditors care much more about whether those targets align with your resource requirements, tooling, and day-to-day business processes. Auditors rarely expect instant recovery. They do expect realism, preparedness, and consistency between what you say and what you can actually execute.

For cloud-native and SaaS teams, continuity planning works best when it reflects real dependencies. If your platform relies on cloud infrastructure, identity providers, and third-party services, your continuity scenarios should account for vendor outages, degraded service, and communication with customers, not just internal system failures. Ignoring those dependencies is one of the fastest ways to end up with a policy that looks fine on paper but falls apart in a real incident.

AI companies face a similar challenge, but with different emphasis. Business continuity is often less about restoring a single server and more about ensuring the availability of information, protecting training data, preserving model integrity, and being able to safely redeploy or roll back changes without introducing new risk. The best continuity programs reflect those realities rather than forcing AI workloads into a traditional IT recovery model.

There’s a faster, easier way to get ISO 27001 certified

Many teams reach this point in the ISO 27001 process feeling stuck between spreadsheets, half-written policies, and conflicting advice about what ISO 27001 compliance actually requires.

Secureframe gives you a faster, clearer path to ISO 27001 by combining audit-ready policy templates, guided implementation, and real-time visibility into your controls, risks, and audit evidence. Instead of guessing whether your business continuity policy is sufficient, you can build it with confidence using templates aligned to ISO 27001 requirements, get expert guidance when you need it, and track testing, reviews, and audit readiness in one place.

And because Secureframe supports 40+ frameworks including SOC 2, GDPR, and NIST standards, the work you do for business continuity becomes part of a scalable compliance program that grows with your organization.

Request a demo to see how Secureframe can help you get ISO 27001 certified faster, with less guesswork and far less manual effort.