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ISMS Scope Extension and Multi-Site Plan Template (ISO/IEC 27001)

Scope change classification, ISMS impact by clause, multi-site eligibility, site register and sampling groups, site readiness checklist, CB notification log, timeline

ISMS und ISO/IEC 27001VollständigISO/IEC 27001:2022 + Amd 1:2024 clauses 4.3, 6.3, 8.1 (cited only); ISO/IEC 17021-1:2015; ISO/IEC 27006-1:2024; Global ACI-TECH-3-001 (ex IAF MD 1)scopeextensionmultisiteplan

Anleitung: Use it when the certified ISMS scope changes: new sites, services, legal entities or countries, a scope reduction, or a phased multi-site certification. Fill the scope comparison and the central function eligibility check first. The main pitfall is updating the scope statement without running the new site through risk assessment, SoA, internal audit and management review before the certification body visits.

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Scope Extension and Multi-Site Plan: [Organization name] ISMS

Plans a change to the certified scope of an information security management system (ISMS): adding sites, services, products, legal entities or countries, reducing scope, or moving a multi-site organization onto one certificate. It supports ISO/IEC 27001:2022 + Amd 1:2024 clauses 4.3 (scope), 6.3 (planning of changes) and 8.1, and prepares the conversation with the certification body, which applies ISO/IEC 17021-1:2015, ISO/IEC 27006-1:2024 and the accreditation community's multi-site mandatory document (IAF MD 1, now carried over by Global ACI as Global ACI-TECH-3-001). Replace every [bracketed] value and every row marked Example.

Document control

FieldValue
Document IDDOC-ISMS-095
Version[1.0]
Status[Draft / In review / Approved / Closed]
Owner[@isms-manager]
Approvers/reviewers[@ciso], [@top-management-sponsor], [@site-managers]
Last updatedYYYY-MM-DD
Classification[Internal]
Standard and editionISO/IEC 27001:2022 + Amd 1:2024; ISO/IEC 17021-1:2015; ISO/IEC 27006-1:2024; Global ACI-TECH-3-001 v1.0 (based on IAF MD 1:2023)
Next scheduled review[YYYY-MM-DD, or at closure of the extension]
Current certificate[Certificate number, issue date, expiry date]
Certification body[CB name] (accredited by [accreditation body], a signatory of the Global ACI MRA, formerly IAF MLA)
Change type[New site / New service / New legal entity / New country / Scope reduction / Multi-site consolidation]
Linked documentsISMS scope DOC-ISMS-002, ISMS change plan DOC-ISMS-025, Certification cycle plan DOC-ISMS-094, SoA DOC-ISMS-011

Approvals

RoleNameDecisionDate
ISMS manager[@isms-manager][Prepared]YYYY-MM-DD
Top management sponsor[@sponsor][Approved / Approved with changes]YYYY-MM-DD
Site or service owner[@site-manager][Agreed]YYYY-MM-DD

Revision history

VersionDateAuthorChange
1.0YYYY-MM-DD[@isms-manager]First issue
[x.y]YYYY-MM-DD[@author][Change summary]

Contents

1. Purpose and trigger

This plan governs the change of the ISMS scope described below, from the decision to extend (or reduce) through the certification body's decision to amend the certificate. It makes sure the change is planned (clause 6.3), that the new boundary is documented (clause 4.3), that operational controls are in place before the new part is declared in scope (clause 8.1), and that the certification body is told in time.

FieldEntry
Trigger[Acquisition / New site opened / Customer requirement / New service launched / Regulatory requirement / Phased certification]
Business driver[e.g. tender requires certificate to name the new plant]
Required date on the certificate[YYYY-MM-DD]
Decision taken by[Steering committee, minute reference]
Sponsor[@sponsor]

Example (Quillmere Group): the group certified its HQ, data centre and service centre in phase 1 and now extends the certificate to its three plants (phase 2), because two automotive customers require the plants to be named on the certificate by YYYY-MM-DD. Decision recorded in steering committee minute SC-2027-04.

2. What changes in the scope

2.1 Scope statements

ElementCurrent certified scopeProposed scope
Scope statement (certificate wording)[Current text][Proposed text]
Legal entities[Entity A][Entity A, Entity B]
Sites (address)[List][List with new sites marked NEW]
Services and products[List][List with additions marked NEW]
Technology boundary[Cloud tenants, regions, data centres][Additions]
SoA version[vX.Y, date][vX.Z, planned date]
Exclusions[None / list][None / list]

2.2 Change classification

IDChangeTypeInterfaces and dependenciesRisk to the ISMS
EXT-001 (Example)Add Plant A, Plant B, Plant C (phase 2)New sitesGroup SOC at HQ, ERP in group data centre, OT networks at each plantHigh: OT environments not yet covered by the risk assessment
EXT-002 (Example)Add the newly acquired service subsidiary as a legal entityNew legal entitySeparate identity provider, own suppliersMedium: integration of identity and supplier controls
EXT-003[Change][Type][Interfaces][Low / Medium / High]

Define what counts as a scope change for your certificate. Typical examples: a new permanent site, a new legal entity, a new country, a new service offered to customers, a new production hosting region, and removing any of these. A new team inside an existing site and service usually does not change the certificate, but it still goes through the ISMS change process (isms/isms-change-plan).

3. Impact on the ISMS

Run the change through each element of the ISMS and record the update.

ISMS elementClause or controlUpdate requiredOwnerStatus
Context and interested parties (DOC-ISMS-003)4.1, 4.2New local legal requirements, local customers and regulators, climate-related issues at the new site where relevant (Amd 1:2024)[@isms-manager][Open / Done]
Scope (DOC-ISMS-002)4.3New boundary, interfaces and dependencies[@isms-manager][Open / Done]
Legal register (DOC-ISMS-014)4.2, A.5.31Data protection, labour, sector and export rules of the new country[@legal][Open / Done]
Asset inventory (DOC-ISMS-012)A.5.9New information assets, systems and OT assets[@site-it][Open / Done]
Risk assessment and register (DOC-ISMS-016)6.1.2, 8.2Assess new risks with the approved method (DOC-ISMS-010)[@risk-owner][Open / Done]
Risk treatment plan (DOC-ISMS-013)6.1.3, 8.3Treatments for new risks, owners, dates[@risk-owner][Open / Done]
Statement of Applicability (DOC-ISMS-011)6.1.3 dRevisit applicability: physical controls A.7, OT-relevant A.8 controls, site-specific exclusions[@isms-manager][Open / Done]
Objectives (DOC-ISMS-024)6.2Site-level objectives where needed[@site-manager][Open / Done]
Roles and RACI (DOC-ISMS-006)5.3Site security coordinator, local incident contact[@ciso][Open / Done]
Competence and awareness (DOC-ISMS-026)7.2, 7.3Onboarding training for all staff at the new site[@hr][Open / Done]
Documented information (DOC-ISMS-028)7.5Local procedures registered, translations controlled[@doc-controller][Open / Done]
Internal audit (DOC-ISMS-082)9.2Audit of the new site before the CB visit[@internal-audit][Open / Done]
Management review (DOC-ISMS-085)9.3Review covers the extension and its readiness[@sponsor][Open / Done]
Control evidence matrix (DOC-ISMS-033)AllEvidence owners and locations for the new site[@isms-manager][Open / Done]

Climate-related issues: since Amd 1:2024 the context analysis must take a position on climate change (4.1) and look for stakeholder demands linked to it (4.2). A new plant in a flood-prone area, or a data centre with cooling constraints, can make this a real input to the risk assessment rather than a one-line statement.

4. Multi-site eligibility and the central function

A multi-site organization runs one management system across several sites under the authority of a central function. The certification body decides whether the multi-site approach, and site sampling within it, can be used. It applies ISO/IEC 17021-1, the ISMS-specific requirements of ISO/IEC 27006-1:2024 (which take precedence for ISMS), and the general multi-site mandatory document. That document was issued by the International Accreditation Forum as IAF MD 1:2023 and, after IAF's role passed to the Global Accreditation Cooperation Incorporated (Global ACI), was re-issued as Global ACI-TECH-3-001 version 1.0 (issued 2026-07-10, implementation 2026-08-28).

4.1 Self-assessment of eligibility

The criteria below are written in this template's own words. Read the official documents and confirm with your CB.

#Criterion (paraphrased)EvidenceMet?
E1One single ISMS covers all sites: same policy, risk method, SoA, documented information and improvement processPolicy framework DOC-ISMS-005, SoA DOC-ISMS-011[Yes / No]
E2A central function is identified, is part of the organization (not outsourced) and has authority to define and maintain the ISMSRACI DOC-ISMS-006, steering committee charter DOC-ISMS-007[Yes / No]
E3One management review covers the whole ISMS, including every siteManagement review minutes DOC-ISMS-085[Yes / No]
E4Every site is in the internal audit programmeInternal audit programme DOC-ISMS-082[Yes / No]
E5The central function collects and analyses data from all sites (incidents, metrics, audit results, corrective actions, legal changes) and can require change at any sitePerformance report DOC-ISMS-081, corrective action records DOC-ISMS-087[Yes / No]
E6Legal or contractual links bind each site to the central functionGroup structure chart, intra-group agreements[Yes / No]

The central function does not have to sit in one building. It is the place where top management authority over every site is exercised, for example the group security office plus the group steering committee.

4.2 Consequences of a nonconformity at one site

Plan for this before the audit. Under the multi-site rules, a nonconformity found at one site (by your own internal audit or by the CB) must be analysed to decide whether it reflects a system-wide weakness. If it does, correct it at the central function and at every affected site; if it does not, record why the follow-up is limited. A major nonconformity open at any site at the time of the certification decision holds back certification of the whole multi-site organization, and removing the problem site from the scope during the process to avoid this is not accepted. This is why section 6 makes each new site pass an internal audit before the CB sees it.

5. Site register and sampling groups

5.1 Site register

Site IDSiteCountryActivities in scopePersons doing work under the organization's controlVery similar toProposed treatment
SITE-01 (Example)Quillmere Group HQ (central function)Country AGroup management, group security office, shared services[n]NoneAudited at every audit (central function)
SITE-02 (Example)Group data centreCountry AHosting of ERP, identity, OT historian[n]NoneNot sampled
SITE-03 (Example)Service centreCountry BCustomer support, field service planning[n]NoneNot sampled
SITE-04 (Example)Plant ACountry BManufacturing, OT network, warehouse[n]SITE-05, SITE-06Sampling group PLANTS
SITE-05 (Example)Plant BCountry CManufacturing, OT network, warehouse[n]SITE-04, SITE-06Sampling group PLANTS
SITE-06 (Example)Plant CCountry DManufacturing, OT network, warehouse[n]SITE-04, SITE-05Sampling group PLANTS

Quillmere Group has 2,400 staff across these 6 sites in 4 countries. Fill the headcount column from HR data on the same date for every site, and make sure the figures add up to the group total you declare on the CB application form: audit time depends on it.

5.2 How sampling usually works (for planning only)

The general multi-site document lets the CB sample sites only where they perform very similar activities, and requires the CB to have its own documented rules that restrict sampling where risk or complexity is high. Its general approach sets a minimum sample from the square root of the number of sites in a group (rounded up), with a reduced factor for surveillance, at least a quarter of the sample chosen at random, and the central function audited at initial certification, every recertification and at least once each calendar year. Sites that cannot be sampled are audited in full at initial certification and recertification and in part during surveillance. ISO/IEC 27006-1:2024 sets ISMS-specific multi-site requirements that take precedence, so your CB may apply different or additional rules.

ItemPlanning assumptionConfirmed by CB
Sampling group PLANTS: sites in group3 (Example)[Yes / No, date]
Sites visited at the extension audit2 of 3 (Example: square root of 3 is 1.73, rounded up to 2)[CB figure]
Sites visited per surveillance year2 of 3 (Example: 0.6 x 1.73 = 1.04, rounded up to 2)[CB figure]
Non-sampled sites (HQ, data centre, service centre)HQ every audit; data centre and service centre on a rotation set by the CB (Example)[CB figure]
Remote audit of any site[Proposed for which activities][CB decision]

Treat these figures as a planning aid for budget and site preparation. Do not quote them to management as commitments until the CB confirms them in writing in the audit programme.

6. Site readiness checklist

#Readiness itemEvidenceMandatoryStatus
R01Site or service described in the updated scope statementScope DOC-ISMS-002 vX.YYes[Yes / No]
R02Site security coordinator named and trainedRACI DOC-ISMS-006, training recordYes[Yes / No]
R03Information assets and systems recordedAsset inventory DOC-ISMS-012Yes[Yes / No]
R04Risks assessed with the group method and recordedRisk register DOC-ISMS-016 entriesYes[Yes / No]
R05Treatments planned, owners and dates setRisk treatment plan DOC-ISMS-013Yes[Yes / No]
R06SoA revised for site-specific controlsSoA DOC-ISMS-011 new versionYes[Yes / No]
R07Local legal and contractual requirements recordedLegal register DOC-ISMS-014Yes[Yes / No]
R08Group policies published at the site, in the local language where neededPolicy acknowledgement reportYes[Yes / No]
R09All staff completed security awareness onboardingTraining completion reportYes[Yes / No]
R10Physical security controls in place (entry, visitors, secure areas)Physical security policy DOC-ISMS-055, site walk recordYes[Yes / No]
R11Access control, logging and backup cover the site's systemsAccess review, log source list, backup reportYes[Yes / No]
R12Internal audit of the site completed, major findings closedInternal audit report DOC-ISMS-084Yes[Yes / No]
R13Incident reporting tested from the siteTest ticket or exercise recordYes[Yes / No]
R14Site included in the next management reviewManagement review agenda or minutesYes[Yes / No]
R15Business continuity and ICT readiness cover the siteBCP DOC-ISMS-121, ICT readiness plan DOC-ISMS-047Where relevant[Yes / No]
R16Suppliers specific to the site assessedSupplier register DOC-ISMS-066Where relevant[Yes / No]
R17Records have operated long enough to be sampled[e.g. 2 months of access reviews and incident logs]Yes[Yes / No]

How long the site must operate before the CB visits is not fixed by ISO/IEC 27001. It is CB practice to expect records that show the controls working, so plan at least one full cycle of the recurring controls (access review, backup test, vulnerability scan) at the new site.

7. Notification and engagement with the certification body

The certification agreement required by ISO/IEC 17021-1 makes the certified client responsible for informing the CB promptly of matters that can affect the ISMS's ability to keep meeting the requirements. In practice this covers changes to legal status, ownership or commercial standing; organization and top management; contact address and sites; the scope of activities covered; and major changes to the ISMS and its processes. Check the exact list in your contract.

7.1 Notification log

IDDate sentChange notifiedSent byCB responseOutcome
CBN-001 (Example)YYYY-MM-DDPhase 2: add Plant A, B and C; revised headcount and site list[@isms-manager]CB requests updated application form and site detailsExtension audit proposed alongside surveillance 1
CBN-002 (Example)YYYY-MM-DDAcquisition of service subsidiary; integration plan[@isms-manager]CB asks for integration status at next surveillanceEntity added after readiness confirmed
CBN-003YYYY-MM-DD[Change][@owner][Response][Outcome]

7.2 Information the CB usually asks for

  • Updated application form: legal entities, sites with addresses, activities per site, persons doing work under the organization's control per site, shift patterns, and outsourced processes.
  • Proposed scope wording and the revised SoA version.
  • Evidence that the central function controls the new sites (section 4).
  • Readiness status per site (section 6) and the internal audit report.
  • Preferred dates, languages spoken at the site and any safety or access constraints (for example, OT areas that need escorted access).

7.3 How the CB may handle the extension

The CB decides the route, and it may differ from what you propose:

RouteWhen it is typically usedPlanning impact
Separate extension auditLarge change, new country, high-risk activitiesExtra audit days, separate date
Extension combined with a surveillance auditChange timed close to a planned surveillanceLonger surveillance, one visit
Extension at recertificationChange near the end of the cycleNo separate visit; risk of waiting
Document review onlyVery small change with low risk (CB judgement)Least effort, CB decides

Whatever the route, the certificate is amended only after the CB's certification decision. Do not advertise the extended scope before the amended certificate is issued (isms/certification-mark-usage).

8. Plan and timeline

MilestonePlanned dateOwnerDone
Scope and impact analysis approved[2027-04-26 (Example)][@isms-manager][ ]
CB notified, application updated[2027-05-03 (Example)][@isms-manager][ ]
Site readiness checklist complete (controls and training done)[2027-07-24 (Example)][@site-managers][ ]
Internal audit of new sites and corrective actions closed[2027-08-28 (Example)][@internal-audit][ ]
Management review held[2027-08-31 (Example)][@sponsor][ ]
CB extension audit (date set by the CB; the gap after the review is scheduling buffer)[2027-09-27 (Example)][CB][ ]
Amended certificate[by 2027-11-01 (Example)][CB][ ]

8.1 Budget

ItemEstimate (USD, Example)
CB extension audit days (CB quotation)[amount]
Auditor travel to plants[amount]
Internal audit of three plants[amount]
Site controls (physical access, OT network monitoring)[amount]
Translation of policies and training[amount]
Total[sum of rows above]

Use local currency where you budget. Feed the total into the budget and resource plan (isms/isms-budget-resource-plan).

9. Scope reduction and site removal

FieldEntry
Part leaving the scope[Site, entity or service]
Reason[Divestment / Closure / Business decision]
Effective dateYYYY-MM-DD
Interfaces that remain (shared systems, data, staff)[Describe; these stay in scope or become supplier relationships]
Information and assets to return, transfer or dispose of[Asset list, disposal records DOC-ISMS-057]
Access to revoke[Accounts, VPN, badges]
Open risks, findings or incidents at that site[List and how they will be closed]
CB notified[CBN-NNN, date]

When a site leaves, check that customer contracts, trust centre pages and marketing material no longer claim it is certified.

10. Size tiers

AspectSmall: Quillmere Analytics Ltd (46 staff)Medium: Quillmere Health Systems (320 staff)Large: Quillmere Group (2,400 staff, 6 sites)
Typical extensionAdd a newly launched product module or a new production region with the same cloud providerBring the managed service and the colocation suite into scope, or add the second officePhase plants into a group certificate; add an acquired subsidiary
Multi-site relevanceUsually none: one office plus remote staff; remote work is covered in the scope, not as sitesTwo offices and a colocation suite; CB decides whether sites are sampled or each auditedFull multi-site approach with a central function and sampling groups
Plan depthSections 1 to 3, 6 and 7 on two pagesAll sections; sampling table shortAll sections; one readiness checklist per site
Who runs itISMS manager (0.5 FTE, Head of Engineering Operations)Full-time ISMS manager with the 3-person security teamCISO's 14-person security office with site coordinators
CB route usually seenDocument review or combined with surveillance (CB decides)Combined with surveillanceSeparate extension audit or combined with surveillance, multi-day
Main riskNew region configured differently from the primary oneColocation provider controls not evidencedOT environments and local language records at plants

11. Records and evidence

RecordProvesOwnerLocationRetention
Steering committee decision to extendPlanned change (6.3), top management direction[@sponsor][Minutes repository][Certificate cycle + 3 years]
This plan, approvedPlanned change and scope definition[@isms-manager][Document management system][Certificate cycle + 3 years]
Revised scope document and SoA versionsClause 4.3, 6.1.3 d[@isms-manager][Document management system][Superseded versions: 3 years]
Risk assessment results for new sitesClause 8.2[@risk-owner][Risk register tool][3 years]
Site readiness checklistsOperational readiness (8.1)[@site-managers][ISMS workspace][Certificate cycle]
Internal audit reports of new sitesClause 9.2[@internal-audit][Audit repository][Certificate cycle + 3 years]
Management review minutes covering the extensionClause 9.3[@sponsor][Minutes repository][Certificate cycle + 3 years]
CB notification log and correspondenceContractual obligations to the CB met[@isms-manager][CB folder][Certificate cycle + 3 years]
CB audit report and amended certificateCertification decision[@isms-manager][CB folder][Life of certificate + 3 years]

Retention periods are examples: set them in the documented information register (isms/isms-documented-information-register) and align with legal requirements. Map each record to its evidence owner in isms/control-evidence-matrix.

12. References

ReferenceEdition and statusUse
ISO/IEC 27001:2022 + Amd 1:2024Current (https://www.iso.org/standard/82875.html, Amd 1: https://www.iso.org/standard/88435.html)Clauses 4.3, 6.3, 8.1
ISO/IEC 17021-1:2015Current (https://www.iso.org/standard/61651.html)Certification process, certification agreement, changes affecting certification
ISO/IEC 27006-1:2024Current (https://www.iso.org/standard/82908.html)ISMS-specific audit time and multi-site requirements applied by the CB
Global ACI-TECH-3-001 (M), multi-site audit and certificationVersion 1.0, issued 2026-07-10, implementation 2026-08-28; based on IAF MD 1:2023 (check the Global ACI document for any changes) (https://global-aci.org/en/global_aci-documents/?cat_id=5)General multi-site eligibility and sampling
Global ACI-TECH-3-002 (M), transfer of accredited certificationVersion 1.0, issued 2026-07-10; based on IAF MD 2:2023When an acquired entity holds a certificate from another CB
Global ACI-TECH-3-003 (M), use of ICT for conformity assessmentVersion 1.0, issued 2026-07-10; based on IAF MD 4:2025Remote audit of sites
Related templatescompliance/ms-scope, isms/isms-change-plan, isms/certification-cycle-plan, isms/certification-body-selection, isms/surveillance-readiness-health-check, isms/certification-mark-usage, compliance/statement-of-applicability, compliance/internal-audit-program, compliance/management-review, isms/control-evidence-matrix, isms/isms-budget-resource-planLinked documents

Standard and licence note

Structure aligned with ISO/IEC 27001:2022 + Amd 1:2024 (clauses 4.3, 6.3 and 8.1), ISO/IEC 17021-1:2015, ISO/IEC 27006-1:2024 and the multi-site mandatory document Global ACI-TECH-3-001 (based on IAF MD 1:2023). The text, tables, criteria wording and examples are original; no ISO, IEC, IAF or Global ACI text is reproduced, and the eligibility criteria and sampling rules are paraphrased for planning only. Read the official standards and mandatory documents, and follow your certification body's procedures, which decide sampling, audit time and the route of any extension. Check the current editions before use: the accreditation mandatory documents were renumbered under Global ACI in 2026. Official ISO text, purchase or licensed access: https://www.iso.org/standard/82875.html, https://www.iso.org/standard/61651.html and https://www.iso.org/standard/82908.html. This is a documentation format, not certification advice.

Template licence: MIT.

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