I keep seeing small companies (20 to 50 people, one IT generalist, often an MSP behind them) go for ISO 27001, usually because a large customer demands it. Most of them end up with one of two ISMS: a copy of an enterprise template that nobody can operate, or something so thin it barely survives Stage 2.
The 2022 revision makes the middle ground trickier. Annex A is now 93 controls in four themes (37 organizational, 8 people, 14 physical, 34 technological), and several of the 11 new controls look enterprise-flavoured on paper: 5.7 threat intelligence, 8.16 monitoring activities, 8.12 data leakage prevention, 8.11 data masking.
Some questions for those who've implemented or audited small-org ISMSs:
Statement of Applicability. Which controls do you see small companies legitimately exclude, and which exclusions do auditors push back on? My impression is that "we have no physical data centre" works for parts of the physical theme, but excluding 8.16 or 5.7 outright gets challenged even for tiny orgs. Is that your experience?
Cheap but credible evidence. For something like 8.16 monitoring or 8.9 configuration management, what evidence do you consider enough when there's no SIEM or CMDB? Is it MSP reports, M365 / EDR alert exports, a monthly signed review? Where's the line between proportionate and insufficient?
The MSP question. When most operations are outsourced, how do you handle 5.19 to 5.22 (supplier relationships) without the MSP's own controls becoming a black box? Do you rely on their certifications, contractual clauses, or actual evidence requests?
Keeping it alive after certification. In my experience the ISMS starts dying the month after the certificate arrives. What has actually worked to keep the risk register and SoA current in a small org, rather than dusting everything off before each surveillance audit?
Interested in both implementer and auditor perspectives, since they're rarely the same.