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The CISO Decision Brief

When do we…

When will certification realistically happen, and what will it cost?

4 decision pointsThe pack behind this answer: ISO 27001 Implementation & Certification Readiness

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The short answer

Recommendation
Work the earliest Stage 2 date out from your own gaps and the operating period, then add the certification body's lead time and its decision after Stage 2. Budget internal staff time first, because it is usually the largest cost, and budget the certification body for the full three-year cycle.
Reasoning
Stage 2 can pass only after the blocking items have produced records for the operating period (IS-05), and adding people does not shorten that. The earliest Stage 2 date is the latest of three: the last gap In place, the last blocking item In place plus the operating period, and the internal audit and management review done. The certificate follows the body's own review, and an open major nonconformity holds it. Audit days, and so fees, depend on the people in scope, the sites and the complexity of the scope. The certificate lapses without the surveillance audits.
Considerations
  • The 38 weeks, 150 to 300 person-days, 10 to 15 audit days, €10,000 to €25,000 and the surveillance and recertification fractions are the pack's estimates for 100 to 300 people. Replace them with your own assessment and quotes.
  • Present the date as a measure that will change. Reassess readiness monthly once controls are being put in place, and move the date early if the evidence says so (IS-10).
  • A quote with far fewer audit days than other accredited bodies offer for the same scope is worth questioning. A certificate from a body without recognised accreditation may not be accepted by your customers.
  • If the date misses a deadline, a narrower first scope helps only if it still passes every scope test. Narrowing it after Stage 1 is expensive.

The decision, step by step

Select any step for the reasoning behind it and where the pack covers it.

  • Start
  • Step
  • Decision
  • Outcome

Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.

Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.

Read as text

The same flow written out: each step, its reasoning and where the pack covers it. 15 steps.
  1. Start

    Someone asks when we will be certified, and for how much

    The question usually comes from a sponsor, a sales team with a tender, or a regulator. An honest answer has two parts, worked out in the same way: a date built from what the auditor needs to see, and a budget in which the largest line is your own people's time.

  2. Step

    Write down the reason for certifying and any fixed deadline

    The reason sets the scope and the date: which customers, tenders or regulators will read the certificate, and by when. If one of them has set a deadline, plan backwards from it phase by phase as well as forwards from today. That shows early whether the two meet.

  3. Decision

    Have you scored readiness and listed gaps with owners?

    A real estimate needs each requirement scored from 0 (Not started) to 3 (Operating), and each gap given an owner and the weeks of work that owner can actually give it. Without that, you can only plan with typical durations. If you are unsure whether your scores are current, answer no.

    In the pack

  4. Step

    Plan with the typical phase durations for now

    The pack's default route is six phases, 38 weeks of elapsed time: decide and scope, assess risk, select and document controls, implement and operate, check, certify. A smaller organisation, or one with more in place, can shorten the first three. The implement-and-operate phase cannot be shortened by adding people: it is the time controls need to produce records. Replace these durations after your first readiness assessment.

  5. Step

    Work out the earliest Stage 2 date from three dates

    (a) When the last gap is In place, with each owner working through their gaps one at a time, blocking items first. (b) When the last blocking item is In place, plus the operating period; the pack's default is 3 months, and your certification body may expect more. (c) When the internal audit and management review are done. The earliest Stage 2 date is the latest of the three.

  6. Decision

    Is the certification body booked for dates that fit?

    Auditors are booked weeks or months ahead, and the date you want may not exist. The pack plans to book by the end of the phase that produces the Statement of Applicability, with a typical lead time of 8 to 12 weeks. If you have not booked, or are unsure the dates hold, answer no.

  7. Step

    Get dates from at least two accredited bodies

    Ask each body for its available dates and for the audit days per stage and per surveillance audit, not only the total. Leave room between Stage 1 and Stage 2: the pack's typical gap is 2 to 8 weeks, long enough to close Stage 1 concerns and short enough that Stage 1 is still current.

  8. Step

    Add the certification decision after Stage 2

    The certificate does not arrive on the day of Stage 2. The certification body's own review usually takes some weeks; the pack's typical figure is 2 to 6 weeks, and only if no major nonconformity is open. A major nonconformity holds the recommendation until it is corrected and verified, which may need a further visit.

    In the pack

  9. Decision

    Does the certificate date meet the deadline you were set?

    Compare the likely certificate date with the deadline from the customer, tender or regulator. If there is no external deadline, compare it with the date top management expects. If you cannot tell yet, answer no and say so: it is better raised at the first gate than discovered at Stage 1.

  10. Step

    Raise it now: add resource, narrow the scope or accept later

    Tell the executive sponsor the same month. More people help only with the work of putting controls in place; they cannot shorten the operating period of records. A narrower first scope can be widened later at a surveillance audit, if it still passes every scope test, but narrowing it after Stage 1 is expensive. If neither closes the gap, tell whoever set the deadline now, then cost the plan you choose.

  11. Step

    Estimate internal effort first: it is the largest cost

    The pack estimates 150 to 300 person-days in total for 100 to 300 people, mostly the ISMS manager and the control owners. Budget it as time released from other work, or the project slips when controls are being put in place. Add the cost of closing each gap, such as backup or logging tools, budgeted per gap from the gap tracker.

  12. Step

    Budget the certification body for the full three-year cycle

    The pack's estimates, to be replaced by quotes: 10 to 15 audit days and about €10,000 to €25,000 for Stage 1 and Stage 2; surveillance audits in years two and three at about a third of the initial fee each; recertification at about two thirds of it every three years. The certificate lapses without the surveillance audits. Training, a contracted internal auditor and consultancy are optional.

  13. Decision

    Does any quote offer far fewer audit days, or lack accreditation?

    Audit days depend mainly on the number of people in scope, the number of sites and the complexity of the scope, under the rules the body is accredited to. A quote with fewer days than other accredited bodies offer for the same scope is worth questioning. A certificate from a body without recognised accreditation may not be accepted by the customers you are certifying for.

  14. Step

    Question that quote before you rely on it

    Ask the body how it arrived at its audit days for your scope and whether the quote covers the whole three-year cycle. Compare it line by line with the other quotes. Drop a body whose accreditation your customers or regulator would not recognise.

  15. Outcome

    Take the date and budget to top management for approval

    Top management approves the scope, the policy and the resources before the project starts. Depending on how you are governed, that is the board or a committee it has delegated to, the management board in a two-tier structure, or executive management where there is no board. Present the date as a measure that will change: reassess readiness monthly once controls are being put in place, and move the date early if the evidence says so.

Practical checklist

  1. Write down the reason for certifying and any fixed deadline, and plan backwards from it as well as forwards.
  2. Score readiness and list each gap with an owner and the weeks of work they can give it, or use typical durations for now.
  3. Work out the earliest Stage 2 date as the latest of the three dates.
  4. Get dates and audit days per stage and per surveillance audit from at least two accredited bodies.
  5. Add the certification decision after Stage 2, and compare the certificate date with the deadline.
  6. Tell the executive sponsor the same month if it misses: add resource, narrow the scope or accept a later date.
  7. Estimate internal effort and the cost of closing each gap, then the external costs for the three-year cycle.
  8. Take the date and budget to top management for approval.

Evidence to have ready

  • The readiness assessment and gap tracker the Stage 2 estimate is worked out from.
  • Quotes from at least two accredited certification bodies, with audit days per stage and per surveillance audit.
  • The budget, showing internal effort as time released from other work and the per-gap costs.
  • Top management's approval of the scope, policy and resources (IS-01).
  • The monthly readiness reassessments and any decision to move the date.

Assumptions

  • Durations and costs are the CISO Times ISO 27001 pack's defaults for an organisation of 100 to 300 people starting with some controls in place. They are estimates, not prices or quotes. Your own readiness assessment and quotes replace them.
  • You are certifying to ISO/IEC 27001:2022 with an accredited certification body.

Not covered here