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Risk Acceptance Record Template (ISO/IEC 27001 6.1.3 f)

One record per accepted risk: scores before and after, rationale, compensating controls, conditions, expiry, approver per band, lifecycle, register

SGSI e ISO/IEC 27001CompletaISO/IEC 27001:2022 + Amd 1:2024 clauses 6.1.2 a, 6.1.3 f, 8.3 (cited only); ISO/IEC 27005:2022riskacceptancerecord

Cómo usar: Use it whenever a High or Critical residual risk, or a risk above its category appetite, is retained. Fill the risk, the scores and the reason treatment stops here first, then route to the approver for the band. The main pitfall is open-ended acceptance with no calendar expiry, or acceptance by someone without authority for the band.

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Risk Acceptance Record: [Risk ID and short title]

A record of the formal decision to accept one information security risk at a stated residual level, for a limited time and on stated conditions, by a person with the authority for that risk band. It holds the risk description, the score before and after treatment, the rationale, the compensating controls, the conditions, the expiry and review dates and the approval, followed by the register of all acceptances. It supports the residual risk acceptance by risk owners that ISO/IEC 27001:2022 + Amd 1:2024 clause 6.1.3 f expects, using the acceptance criteria set under clause 6.1.2 a (DOC-ISMS-015), and provides part of the risk treatment results retained under clause 8.3. Replace every [bracketed] value and every row marked Example.

Document control

FieldValue
Document IDDOC-ISMS-019
Version[1.0]
Status[Draft / In review / Approved / Superseded]
Owner[@isms-manager]
Approvers/reviewers[@ciso], [@ceo]
Last updatedYYYY-MM-DD
Classification[Confidential]
Standard and editionISO/IEC 27001:2022 + Amd 1:2024 (clauses 6.1.2 a, 6.1.3 f, 8.3); ISO/IEC 27005:2022
Acceptance criteriaDOC-ISMS-015 version [x.y], section 9
Risk registerDOC-ISMS-016
Treatment planDOC-ISMS-013
Active acceptances[Number, from section 6]
Next scheduled reviewYYYY-MM-DD

Approvals

RoleNameDecisionDate
ISMS manager[@isms-manager][Prepared the record set]YYYY-MM-DD
CISO or security lead[@ciso][Reviewed]YYYY-MM-DD
Top management[@ceo][Approved the form and routing]YYYY-MM-DD

Revision history

VersionDateAuthorChange
1.0 (Example)YYYY-MM-DD[@isms-manager]First issue with the approved acceptance criteria
[x.y]YYYY-MM-DD[@author][Change summary]

Contents

1. When an acceptance record is required

Create one record per risk when any of these is true:

TriggerExample (Example)
Residual score is High (10 to 16) or Critical (17 to 25)A legacy component cannot be replaced before next year
Residual risk exceeds the appetite of its category in DOC-ISMS-015 section 3A Medium confidentiality risk in a category marked Averse
Treatment is rejected as not cost-effective for a risk above LowFull redundancy would cost more than the expected loss
A planned treatment is delayed beyond its due date and the risk stays above appetiteHardware supply delays laptop replacement
Top management chooses to retain a risk after a major incident reviewInterim acceptance while a redesign is funded
An acceptance is renewed after expirySecond six-month acceptance for the same risk

No record is needed for Low risks within appetite and for Medium risks within the appetite of their category: those are accepted by the risk owner in the register (DOC-ISMS-016) with a date and expiry.

What cannot be accepted:

  • a risk that would knowingly breach a law, regulation or binding contract term;
  • a Critical risk without immediate interim measures and a documented top management decision;
  • a risk whose owner has not been identified.

2. Approval authority by band

Residual bandApproverMaximum period (Example)Must also be informed
Medium (5 to 9)Risk owner and department head; top management if the category is Averse12 monthsISMS manager
High (10 to 16)Top management ([CEO / COO / delegated executive])6 monthsSteering committee
Critical (17 to 25)Not acceptable without treatment; exceptionally top management by documented decision3 monthsBoard or owners where one exists; steering committee

Rules applied in every record:

  1. The approver must be independent of the person proposing the acceptance where practical; a risk owner never approves their own High or Critical acceptance alone.
  2. The CISO or ISMS manager reviews every record before approval and records an opinion (agree or disagree with reasons). The approver may decide against that opinion, but the disagreement stays on record.
  3. An acceptance expires at the earlier of its expiry date and the date any condition in Part E is broken.

3. Acceptance record form

Part A: Risk

FieldValue
Acceptance ID[ACC-NNN]
Risk ID (register)[R-NNN]
Risk title[Short title]
Description (cause, event, consequence)[Text]
Catalogue references[THR-NNN, VUL-NNN from DOC-ISMS-018]
Assets or processes affected[From DOC-ISMS-012]
Risk category and appetite[Category / Averse, Cautious or Open]
Risk owner[@risk-owner]
Proposed by[@proposer]
Date proposedYYYY-MM-DD

Part B: Scores before and after

MeasureLikelihoodImpactScoreBandBasis
Current, with existing controls[1 to 5][1 to 5][L x I][Band][Evidence for ratings]
With compensating controls in Part D[1 to 5][1 to 5][L x I][Band][Why the controls change the rating]
Target if full treatment were applied[1 to 5][1 to 5][L x I][Band][Treatment considered in Part C]

The residual score being accepted is the second row.

Part C: Rationale and options considered

OptionConsidered?OutcomeReason
Modify (reduce)[Yes / No][Chosen in part / Rejected][Cost, feasibility, timing]
Avoid[Yes / No][Rejected][Business impact of stopping the activity]
Share (transfer)[Yes / No][Chosen in part / Rejected][Insurance or contract position]
Retain (accept)YesProposed[Why retaining the residual is reasonable now]

Business justification: [What the organization gains or protects by accepting; what it would cost to treat further; why now].

Part D: Compensating controls

ControlAnnex A referenceOwnerStatusEvidence
[Control description][A.x.y short label][@control-owner][In place / Due YYYY-MM-DD][Record or system]

Part E: Conditions

List the conditions that must stay true for the acceptance to remain valid (for example "no customer personal data stored in the component", "monthly access review completed"). Breaking any condition ends the acceptance.

No.ConditionHow monitoredMonitored by
1[Condition][Metric, review or alert][@owner]

Part F: Expiry, review and exit

FieldValue
Acceptance startYYYY-MM-DD
Review date (before expiry)YYYY-MM-DD
Expiry dateYYYY-MM-DD (within the maximum period for the band)
Early review triggers[Incident affecting the risk, change to the asset, threat intelligence, condition breach]
Exit plan[Treatment that will end the need for acceptance, with RTP reference and date]

Part G: Review and approval

RoleNameOpinion or decisionDate
Risk owner[@risk-owner][Proposes acceptance]YYYY-MM-DD
ISMS manager or CISO[@ciso][Agrees / Disagrees, with reason]YYYY-MM-DD
Approver for the band[@approver][Accepted / Accepted with conditions / Rejected]YYYY-MM-DD
Informed[Steering committee / board][Minute reference]YYYY-MM-DD

Part H: Decision record

FieldValue
Decision[Accepted / Accepted with additional conditions / Rejected, treat instead]
Additional conditions set by the approver[Text or "None"]
Register updated[Yes, DOC-ISMS-016 updated YYYY-MM-DD]
Treatment plan updated[Yes, RTP-NNN / Not applicable]

4. Worked example

ACC-001 (Example): R-018 legacy export service without single sign-on

FieldValue
Risk IDR-018
DescriptionThe legacy scheduled export service uses local accounts instead of the identity provider, so a leaver's account could remain usable and export customer datasets (confidentiality)
Catalogue referencesTHR-006, VUL-013, VUL-001
Category and appetiteConfidentiality of customer and personal data / Averse
Risk ownerHead of Product
Proposed2027-03-25
MeasureLIScoreBand
Current, with existing controls3412High
With compensating controls248Medium
Target with full treatment (service replaced)144Low

Rationale: replacing the service is planned with the new data platform in Q3 2027 (RTP-019). Rebuilding authentication in the legacy service for six months would cost about USD 40,000 in engineering time (Example; use local currency), more than the compensating controls below, which cost about USD 6,000.

Compensating controls:

ControlAnnex A referenceStatus
Access only from the VPN, which requires MFA through the identity providerA.8.5 secure authenticationIn place
Local accounts reviewed monthly against the HR leaver listA.5.18 access rights provisioning and reviewIn place
Export volume alerts sent to the on-call engineerA.8.16 monitoring activitiesIn place
No new customers onboarded to the legacy serviceA.8.3 restricting access to informationIn place

Conditions: (1) monthly review completed and recorded; (2) no new customers on the service; (3) replacement remains funded and dated.

Expiry and approval: the residual band is Medium, but the category is Averse, so DOC-ISMS-015 section 9 escalates approval one level to top management. Start 2027-04-01, review 2027-09-01, expiry 2027-09-30. Reviewed by the ISMS manager (Head of Engineering Operations, part-time 0.5 FTE) on 2027-03-29 with the opinion "agree"; accepted by the CEO on 2027-03-31.

5. Lifecycle of an acceptance

StateMeaningEffect in the risk register
DraftBeing prepared by the risk ownerRisk shown as open
SubmittedWaiting for review and approvalRisk shown as open, decision pending
ActiveAccepted and within its periodRisk shown as accepted with expiry
UnderReviewReview date reached or a trigger occurredRisk shown as accepted, review in progress
RejectedApprover declined; treatment requiredRisk returns to treatment in DOC-ISMS-013
ClosedTreatment completed or risk goneRisk rescored or closed
RevokedA condition was brokenRisk shown as open; escalated
ExpiredExpiry passed without renewalRisk shown as open; reported as overdue

6. Register of acceptances

ACC IDRisk IDTitleResidualApproverStartExpiryStatus
ACC-001 (Example)R-018Legacy export service without single sign-on8 Medium (Averse category)CEO2027-04-012027-09-30Active
ACC-002 (Example)R-024Recovery in the DR region exceeds the internal recovery time objective (contractual recovery times still met); full active-active design rejected as not cost-effective8 MediumHead of Engineering Operations and CTO2027-04-012028-03-31Active
ACC-003 (Example)R-012Embedded charting component from a supplier is out of vendor support until replacement12 HighCEO2027-05-212027-11-21Active
ACC-004 (Example)R-007Contractor laptops not enrolled in MDM during migration9 MediumHead of Engineering Operations and CTO2027-02-152027-08-15Closed
ACC-005 (Example)R-015Shared admin account on the marketing website10 HighCEO2027-05-212027-11-21Revoked
ACC-006 (Example)R-021Customer data copied into test environment without masking12 HighCEONot startedNot applicableRejected

Summary (Example, as of 2027-07-31):

StatusCountOf which HighOf which Medium
Active312
Closed101
Revoked110
Rejected110
Total633

ACC-003 and ACC-005 are two of the 14 High acceptances that top management recorded on 2027-05-21 to correct certification finding CBF-2027-01 (see isms/isms-worked-walkthrough); ACC-004 closed when all contractor laptops were enrolled; ACC-005 was revoked at the July monthly review, which found the shared account still used after the condition date; ACC-006 was rejected and the risk treated through test data masking (A.8.11). (Example)

7. Monitoring, renewal and revocation

  • The ISMS manager reviews the register [monthly] and sends a reminder to each risk owner [30] days before the review date.
  • At review, the risk owner proposes one of: renew (new record version with a new expiry, same approval level), treat (link to RTP), or close (risk no longer exists).
  • A renewal of a High acceptance more than [once] requires top management to confirm why treatment is still not feasible, and the steering committee is informed.
  • Any breach of a condition is reported to the ISMS manager within [2] working days; the acceptance is revoked and the risk escalated under DOC-ISMS-015 section 10.
  • Active, expired and revoked acceptances are reported at each management review (DOC-ISMS-085) with counts by band, and in the ISMS performance report (DOC-ISMS-081).
  • Each annual risk assessment (DOC-ISMS-017) lists all active acceptances and confirms they still reflect the current score.

8. Relationship to security exceptions

SituationLeading recordLink
A policy or standard requirement cannot be met for a specific system or personSecurity exception request (security/security-exception-request, DOC-ISMS-122)The exception creates or updates a risk in DOC-ISMS-016; if its residual needs approval beyond the risk owner, reference this record
A risk from the risk assessment is retained at a level needing approvalThis record (DOC-ISMS-019)No exception needed unless a policy is also breached
Both applyException request, with this record attachedSame approval level, same expiry

Both routes use the same approval levels from DOC-ISMS-015 section 9.

9. Size tiers

AspectSmall: Quillmere Analytics Ltd (Example)Medium: Quillmere Health Systems (Example)Large or multi-site: Quillmere Group (Example)
Typical active acceptances2 to 55 to 1220 to 40 across sites
Who reviews before approvalPart-time ISMS manager (Head of Engineering Operations, 0.5 FTE)ISMS manager with the security teamCISO's security office; site security coordinator for site risks
High approverCEOCEO or COODivisional managing director for site risks; group executive for group-wide risks
Where the register is keptA tab in the risk register spreadsheetGRC tool or ticketing workflow with approval stepsGroup GRC tool, filtered by site and division
ReportingQuarterly to the CEOMonthly to the steering committeeMonthly to divisional boards, quarterly to the group executive committee
Special casesFew approvers: avoid the CEO approving risks the CEO owns; use an independent board member or investor representative where availablePatient safety risks reviewed by the clinical safety officerOT safety-related risks reviewed by the site safety manager before approval

10. Records and evidence

RecordProvesOwnerLocation (Example)Retention (Example)
Completed acceptance records (ACC-NNN) with approvalsResidual risk accepted by an authorised owner (6.1.3 f)Risk owners; ISMS manager keeps the setGRC tool or document management systemLife of the risk plus 3 years
Register of acceptancesOverview and status of all acceptancesISMS managerDOC-ISMS-019 section 6Current plus dated snapshots for 3 years
Review reminders and renewal decisionsAcceptances are reviewed before expiryISMS managerTicketing system3 years
Condition monitoring evidenceConditions are maintainedControl ownersSystems named in Part E3 years
Management review minutesAcceptances reported to top management (9.3)Steering committee secretaryDOC-ISMS-0856 years
Risk treatment resultsClause 8.3 record retainedISMS managerDOC-ISMS-013 and this record set3 years

11. References

ReferenceEditionUse
ISO/IEC 27001:2022 + Amd 1:20243rd edition 2022; Amd 1 2024-02-23Clauses 6.1.2 a, 6.1.3 f, 8.3, 9.3
ISO/IEC 27005:20224th editionRisk acceptance and treatment guidance
ISO 31000:2018Current; a revision is in progressTreatment options and retention of risk

Related templates: isms/isms-risk-appetite-criteria, compliance/risk-methodology, compliance/risk-register, compliance/risk-treatment-plan, isms/isms-risk-assessment-report, isms/isms-threat-vulnerability-catalogue, security/security-exception-request, compliance/management-review.

Standard and licence note

Structure aligned with ISO/IEC 27001:2022 + Amd 1:2024 (clauses 6.1.2 a, 6.1.3 f and 8.3) and ISO/IEC 27005:2022. Clause numbers are cited only; the form, rules, states, figures and examples are original text written for this template, and all figures are worked examples. No ISO or IEC text is reproduced, and you need the official standards to interpret the requirements. Check the current editions before use. This template does not promise certification; certification decisions belong to the accredited certification body.

Template licence: MIT.

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