On October 14, 2025, ISO quietly published a standard that could be a game changer for Tech and SaaS companies: ISO 27701:2025. While everyone is talking about NIS2 and the AI Act, this revision is flying under the radar. Strategic mistake. This second edition radically transforms privacy governance by becoming the first standalone privacy standard, free from the requirement of prior ISO 27001 certification. Faced with the evolution of the GDPR, the rise of artificial intelligence, and increased cybersecurity requirements, the 2019 version had become insufficient. This regulatory convergence in 2026 (GDPR, AI Act, NIS2) makes ISO 27701:2025 a strategic lever for tech decision-makers who want to transform privacy compliance into a certified competitive advantage.
ISO 27701 is no longer just a supplement to ISO 27001: it is now a comprehensive, independently certifiable privacy management system (PIMS). The 2019 version functioned as an extension of ISO 27001, making it impossible to obtain 27701 certification without first obtaining 27001 certification. This dependency excluded many SMEs and startups that did not have the maturity to deploy a comprehensive information security management system (ISMS). With the 2025 version, organizations can now certify their privacy governance without extensive security measures, democratizing access to international recognition of their data protection practices.
This transformation marks a major recognition: privacy is no longer a subset of security, it is a discipline in its own right. For Tech/SaaS startups and scale-ups, this means that from their very first rounds of fundraising (seed, Series A), they can obtain internationally recognized privacy certification, creating a powerful commercial differentiator against competitors who are content with unverified GDPR compliance statements.
The European and international regulatory context explains this strategic shift. Although demanding, the GDPR does not offer any official international certification enabling organizations to prove their compliance in a tangible and audited manner. The AI Act imposes enhanced data governance for artificial intelligence systems, while cyber insurance increasingly requires recognized certifications to cover risks related to personal data.
Technologically speaking, the widespread adoption of cloud computing, the rise of generative AI, and the increasing complexity of international data transfers have created an urgent need for auditable and measurable frameworks. Organizations must now demonstrate compliance with stricter regulatory authorities and increasingly demanding B2B customers regarding privacy guarantees, particularly in regulated sectors such as healthcare, finance, HR applications, and the public sector.
The autonomy of ISO 27701:2025 is the most disruptive change. While the 2019 version required ISO 27001 certification to be in place, the new edition allows a PIMS (Privacy Information Management System) to be certified completely independently. This openness allows organizations using other IT security standards to implement a privacy standard without overhauling their entire compliance architecture.
For Healthtech and Fintech startups, or any SaaS publisher handling sensitive data, this is a game changer: they can now display "ISO 27701 certified" on their website from the seed or Series A phase, without waiting for full SMSI maturity, which would take an additional 12 to 18 months. This badge of trust accelerates B2B sales cycles, particularly in calls for tenders where proof of privacy compliance is a decisive criterion.
The 2025 version adopts the structure and controls of ISO 27001:2022, whereas the 2019 version was still based on ISO 27001:2013, which is now obsolete. This alignment makes it much easier to integrate PIMS into an existing ISMS and reduces the differences between the two standards. For organizations already certified to ISO 27001:2022, adding ISO 27701 now represents a 4- to 6-month project with approximately 60% of controls shared, compared to 12 months in standalone mode.
The standard also adopts the High-Level Structure (HLS) common to all ISO management standards, enabling seamless integration with ISO 9001 ( quality), ISO 22301 (continuity), and ISO 14001 (environment). This harmonization reduces document redundancy and simplifies the implementation of an integrated management system, which is particularly relevant for fast-growing scale-ups that need to structure their overall governance.
The 2025 version provides a much clearer definition of the responsibilities of controllers and processors, with clearly distinct specific obligations. The 2019 edition created ambiguities regarding shared responsibilities in joint processing, which could lead to potential disputes during GDPR audits.
This clarification is crucial for B2B SaaS publishers, who must precisely define their obligations to their customers in their contracts. A CRM publisher, for example, now knows exactly what its obligations are as a "processor" vis-à-vis the responsibilities of its customer, who acts as a "controller," significantly reducing legal risks and facilitating the negotiation of contractual clauses for the protection of personal data.
ISO 27701:2025 now requires visible and demonstrable commitment from management. This requirement is in line with NIS2, which makes executives criminally liable for cybersecurity issues. Management must demonstrate its genuine involvement by allocating resources dedicated to privacy, setting measurable objectives, and integrating data protection into the organization's overall strategy.
Privacy is no longer an isolated task entrusted to the DPO (Data Protection Officer): it is becoming a subject for management at the COMEX level. This evolution transforms privacy from a technical constraint into a strategic issue, particularly crucial for tech companies seeking to raise funds or enter into partnerships with large groups that are sensitive to ESG governance issues.
The new edition requires a proactive and structured approach to Privacy Risk Assessment. Organizations must specifically assess the risks associated with the cloud, artificial intelligence, automation, international transfers, and sensitive data. This analysis is not limited to a documentary exercise: it must establish a clear strategy linking the identified risks to data protection objectives and the processing measures put in place.
Unlike the GDPR's impact assessment (AIPD), which is carried out on a processing-by-processing basis, the ISO 27701 Privacy Risk Assessment takes a strategic and comprehensive view, becoming a true dashboard for management. This approach allows resources, controls, and measures to be dynamically adapted to the real challenges facing the organization in a constantly evolving digital environment.
The 2025 version explicitly addresses issues related to generative AI, hybrid cloud, and the processing of massive volumes of personal data. It provides concrete guidance on the management of personal data in these complex digital ecosystems, whereas the 2019 version only partially addressed these technological contexts.
This update creates powerful synergies with ISO 42001 (AI management): a startup or scale-up developing artificial intelligence solutions can now prove its simultaneous compliance with the GDPR and the AI Act through dual ISO 27701 + ISO 42001 certification . The new controls added cover Threat Intelligence and cloud services, critical areas for modern SaaS companies. The standard incorporates 11 new controls while removing 52 controls not directly related to privacy, thus focusing efforts on what really matters.
ISO 27701:2025 requires much more precise and structured documentation: detailed records, proof of compliance, regular reviews of processing operations, and formalized notification processes. While this change increases the documentation burden, it offers significant legal protection during audits or inspections by data protection authorities.
This enhanced traceability enables organizations to easily demonstrate their compliance, with evidence that can be used in proceedings before the CNIL or equivalent authorities in other jurisdictions. Automation via GRC (Governance, Risk & Compliance) tools such as Oversecur is becoming essential to avoid overburdening compliance teams with manual tasks, while maintaining the quality and completeness of the required documentation.
Startups can now obtain privacy certification right from the outset, without the burden of full ISO 27001 certification. A Healthtech startup that processes health data can use ISO 27701 as an immediate commercial differentiator against non-certified competitors. The implementation timeframe is between 6 and 9 months, compared to 12 to 18 months for a combined ISO 27001 + 27701 process.
This "ISO 27701 certified" trust badge accelerates the closing of business deals by providing tangible, audited proof of GDPR compliance, which is much more convincing than a simple self-assessed compliance statement. For investors, this certification also signals early organizational maturity, reassuring them of the startup's ability to manage regulatory risks.
Fast-growing companies often have mature GDPR compliance teams but lack external recognition of this maturity. ISO 27701 transforms this invisible work into a commercially valuable badge, particularly in enterprise tenders where large accounts (banks, healthcare, public sector) require third-party verified privacy certifications.
Certification also helps to further structure and professionalize privacy processes during a scaling phase, when growth can undermine compliance practices. It facilitates the integration of privacy into the corporate culture, beyond the technical team alone.
Companies developing artificial intelligence solutions are facing increasing regulatory pressure with the European AI Act. The combination of ISO 27701 (privacy) and ISO 42001 (AI governance) offers a powerful certified duo for demonstrating a "Trustworthy AI" approach.
The postponement of the AI Act until the end of 2027 creates an ideal window of opportunity to anticipate and obtain this dual certification before the requirements become mandatory. Organizations can thus position themselves as pioneers in ethical and compliant AI, creating a sustainable competitive advantage in a market that is increasingly sensitive to issues of responsible use of data and algorithms.
ISO 27001:2022 certified companies benefit from a natural extension with approximately 60% of existing controls being shared. The ISO 27701 certification audit can even be carried out simultaneously with the annual ISO 27001 surveillance audit, thus optimizing time and costs.
This additional certification requires approximately 40% marginal effort compared to the work already done for ISO 27001, offering a particularly attractive ROI. It complements the compliance posture by adding the specific privacy dimension (individual rights, CNIL notification, controller/processor roles) not covered by ISO 27001, which focuses on information security.
ISO 27701:2025 was officially published on October 14, 2025. Organizations already certified to the 2019 version have a transition period of 24 to 36 months to migrate to the new edition. New certifications must comply with the 2025 version from now on.
To maximize strategic impact, a recommended deadline is in the fourth quarter of 2026, allowing companies to capitalize on regulatory convergence (NIS2, AI Act, potential Digital Omnibus) and be among the first to become certified before the standard becomes an essential market requirement.
If you do not yet have ISO 27001 certification: Immediately conduct a gap analysis between your current GDPR compliance and the requirements of ISO 27701:2025. Plan to launch the project in the first quarter of 2026 with the aim of achieving certification between the third and fourth quarters of 2026, i.e., a 9-month cycle. Focus your efforts on management governance, privacy risk assessment, and document structuring.
If you already hold ISO 27001:2022 certification: Conduct a delta analysis identifying additional controls specific to privacy. Integrate ISO 27701 preparation into your 2026 surveillance audit with 4 to 6 months of preparation time. Focus particularly on clarifying the roles of controller/processor and privacy specifics (exercise of individual rights, notification process to authorities).
If you are ISO 27701:2019 certified: Perform a gap analysis between the 2019 and 2025 versions without delay, covering the seven structural changes. You must transition before October 2027-2028. Prioritize strengthening management governance, implementing Privacy Risk Assessment, and aligning with ISO 27001:2022 if you have not already done so.
The relationship with the GDPR deserves clarification: ISO 27701 is not a legal requirement but constitutes internationally recognized proof of compliance. For organizations that already have a mature DPO, certification enhances and structures existing work by making it auditable and certifiable.
In the context of the potential Digital Omnibus, which could weaken certain GDPR requirements, ISO 27701 offers a defensive strategy: certified organizations demonstrate their commitment to high standards of data protection, regardless of future regulatory developments. If the GDPR were to be relaxed, ISO 27701-certified companies would retain market confidence thanks to this external recognition of their practices.
ISO 27701:2025 is not just a technical update. It is an opportunity to transform privacy protection from a GDPR risk into a certified competitive advantage. The first companies to obtain certification will become the "Privacy by Design" leaders of tomorrow, ideally positioned when ISO 27701 becomes a standard prerequisite in corporate tenders, as ISO 27001 already is today. The question is no longer "should we get certified?" but "when should we start in order to be among the pioneers?"
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