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
사용법: 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
| Field | Value |
|---|---|
| Document ID | DOC-ISMS-019 |
| Version | [1.0] |
| Status | [Draft / In review / Approved / Superseded] |
| Owner | [@isms-manager] |
| Approvers/reviewers | [@ciso], [@ceo] |
| Last updated | YYYY-MM-DD |
| Classification | [Confidential] |
| Standard and edition | ISO/IEC 27001:2022 + Amd 1:2024 (clauses 6.1.2 a, 6.1.3 f, 8.3); ISO/IEC 27005:2022 |
| Acceptance criteria | DOC-ISMS-015 version [x.y], section 9 |
| Risk register | DOC-ISMS-016 |
| Treatment plan | DOC-ISMS-013 |
| Active acceptances | [Number, from section 6] |
| Next scheduled review | YYYY-MM-DD |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| 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
| Version | Date | Author | Change |
|---|---|---|---|
| 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
- 2. Approval authority by band
- 3. Acceptance record form
- 4. Worked example
- 5. Lifecycle of an acceptance
- 6. Register of acceptances
- 7. Monitoring, renewal and revocation
- 8. Relationship to security exceptions
- 9. Size tiers
- 10. Records and evidence
- 11. References
- Standard and licence note
1. When an acceptance record is required
Create one record per risk when any of these is true:
| Trigger | Example (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 3 | A Medium confidentiality risk in a category marked Averse |
| Treatment is rejected as not cost-effective for a risk above Low | Full redundancy would cost more than the expected loss |
| A planned treatment is delayed beyond its due date and the risk stays above appetite | Hardware supply delays laptop replacement |
| Top management chooses to retain a risk after a major incident review | Interim acceptance while a redesign is funded |
| An acceptance is renewed after expiry | Second 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 band | Approver | Maximum period (Example) | Must also be informed |
|---|---|---|---|
| Medium (5 to 9) | Risk owner and department head; top management if the category is Averse | 12 months | ISMS manager |
| High (10 to 16) | Top management ([CEO / COO / delegated executive]) | 6 months | Steering committee |
| Critical (17 to 25) | Not acceptable without treatment; exceptionally top management by documented decision | 3 months | Board or owners where one exists; steering committee |
Rules applied in every record:
- 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.
- 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.
- 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
| Field | Value |
|---|---|
| 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 proposed | YYYY-MM-DD |
Part B: Scores before and after
| Measure | Likelihood | Impact | Score | Band | Basis |
|---|---|---|---|---|---|
| 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
| Option | Considered? | Outcome | Reason |
|---|---|---|---|
| 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) | Yes | Proposed | [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
| Control | Annex A reference | Owner | Status | Evidence |
|---|---|---|---|---|
| [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. | Condition | How monitored | Monitored by |
|---|---|---|---|
| 1 | [Condition] | [Metric, review or alert] | [@owner] |
Part F: Expiry, review and exit
| Field | Value |
|---|---|
| Acceptance start | YYYY-MM-DD |
| Review date (before expiry) | YYYY-MM-DD |
| Expiry date | YYYY-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
| Role | Name | Opinion or decision | Date |
|---|---|---|---|
| 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
| Field | Value |
|---|---|
| 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
| Field | Value |
|---|---|
| Risk ID | R-018 |
| Description | The 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 references | THR-006, VUL-013, VUL-001 |
| Category and appetite | Confidentiality of customer and personal data / Averse |
| Risk owner | Head of Product |
| Proposed | 2027-03-25 |
| Measure | L | I | Score | Band |
|---|---|---|---|---|
| Current, with existing controls | 3 | 4 | 12 | High |
| With compensating controls | 2 | 4 | 8 | Medium |
| Target with full treatment (service replaced) | 1 | 4 | 4 | Low |
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:
| Control | Annex A reference | Status |
|---|---|---|
| Access only from the VPN, which requires MFA through the identity provider | A.8.5 secure authentication | In place |
| Local accounts reviewed monthly against the HR leaver list | A.5.18 access rights provisioning and review | In place |
| Export volume alerts sent to the on-call engineer | A.8.16 monitoring activities | In place |
| No new customers onboarded to the legacy service | A.8.3 restricting access to information | In 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
| State | Meaning | Effect in the risk register |
|---|---|---|
| Draft | Being prepared by the risk owner | Risk shown as open |
| Submitted | Waiting for review and approval | Risk shown as open, decision pending |
| Active | Accepted and within its period | Risk shown as accepted with expiry |
| UnderReview | Review date reached or a trigger occurred | Risk shown as accepted, review in progress |
| Rejected | Approver declined; treatment required | Risk returns to treatment in DOC-ISMS-013 |
| Closed | Treatment completed or risk gone | Risk rescored or closed |
| Revoked | A condition was broken | Risk shown as open; escalated |
| Expired | Expiry passed without renewal | Risk shown as open; reported as overdue |
6. Register of acceptances
| ACC ID | Risk ID | Title | Residual | Approver | Start | Expiry | Status |
|---|---|---|---|---|---|---|---|
| ACC-001 (Example) | R-018 | Legacy export service without single sign-on | 8 Medium (Averse category) | CEO | 2027-04-01 | 2027-09-30 | Active |
| ACC-002 (Example) | R-024 | Recovery in the DR region exceeds the internal recovery time objective (contractual recovery times still met); full active-active design rejected as not cost-effective | 8 Medium | Head of Engineering Operations and CTO | 2027-04-01 | 2028-03-31 | Active |
| ACC-003 (Example) | R-012 | Embedded charting component from a supplier is out of vendor support until replacement | 12 High | CEO | 2027-05-21 | 2027-11-21 | Active |
| ACC-004 (Example) | R-007 | Contractor laptops not enrolled in MDM during migration | 9 Medium | Head of Engineering Operations and CTO | 2027-02-15 | 2027-08-15 | Closed |
| ACC-005 (Example) | R-015 | Shared admin account on the marketing website | 10 High | CEO | 2027-05-21 | 2027-11-21 | Revoked |
| ACC-006 (Example) | R-021 | Customer data copied into test environment without masking | 12 High | CEO | Not started | Not applicable | Rejected |
Summary (Example, as of 2027-07-31):
| Status | Count | Of which High | Of which Medium |
|---|---|---|---|
| Active | 3 | 1 | 2 |
| Closed | 1 | 0 | 1 |
| Revoked | 1 | 1 | 0 |
| Rejected | 1 | 1 | 0 |
| Total | 6 | 3 | 3 |
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
| Situation | Leading record | Link |
|---|---|---|
| A policy or standard requirement cannot be met for a specific system or person | Security 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 approval | This record (DOC-ISMS-019) | No exception needed unless a policy is also breached |
| Both apply | Exception request, with this record attached | Same approval level, same expiry |
Both routes use the same approval levels from DOC-ISMS-015 section 9.
9. Size tiers
| Aspect | Small: Quillmere Analytics Ltd (Example) | Medium: Quillmere Health Systems (Example) | Large or multi-site: Quillmere Group (Example) |
|---|---|---|---|
| Typical active acceptances | 2 to 5 | 5 to 12 | 20 to 40 across sites |
| Who reviews before approval | Part-time ISMS manager (Head of Engineering Operations, 0.5 FTE) | ISMS manager with the security team | CISO's security office; site security coordinator for site risks |
| High approver | CEO | CEO or COO | Divisional managing director for site risks; group executive for group-wide risks |
| Where the register is kept | A tab in the risk register spreadsheet | GRC tool or ticketing workflow with approval steps | Group GRC tool, filtered by site and division |
| Reporting | Quarterly to the CEO | Monthly to the steering committee | Monthly to divisional boards, quarterly to the group executive committee |
| Special cases | Few approvers: avoid the CEO approving risks the CEO owns; use an independent board member or investor representative where available | Patient safety risks reviewed by the clinical safety officer | OT safety-related risks reviewed by the site safety manager before approval |
10. Records and evidence
| Record | Proves | Owner | Location (Example) | Retention (Example) |
|---|---|---|---|---|
| Completed acceptance records (ACC-NNN) with approvals | Residual risk accepted by an authorised owner (6.1.3 f) | Risk owners; ISMS manager keeps the set | GRC tool or document management system | Life of the risk plus 3 years |
| Register of acceptances | Overview and status of all acceptances | ISMS manager | DOC-ISMS-019 section 6 | Current plus dated snapshots for 3 years |
| Review reminders and renewal decisions | Acceptances are reviewed before expiry | ISMS manager | Ticketing system | 3 years |
| Condition monitoring evidence | Conditions are maintained | Control owners | Systems named in Part E | 3 years |
| Management review minutes | Acceptances reported to top management (9.3) | Steering committee secretary | DOC-ISMS-085 | 6 years |
| Risk treatment results | Clause 8.3 record retained | ISMS manager | DOC-ISMS-013 and this record set | 3 years |
11. References
| Reference | Edition | Use |
|---|---|---|
| ISO/IEC 27001:2022 + Amd 1:2024 | 3rd edition 2022; Amd 1 2024-02-23 | Clauses 6.1.2 a, 6.1.3 f, 8.3, 9.3 |
| ISO/IEC 27005:2022 | 4th edition | Risk acceptance and treatment guidance |
| ISO 31000:2018 | Current; a revision is in progress | Treatment 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.
Official text: https://www.iso.org/standard/82875.html, https://www.iso.org/standard/88435.html, https://www.iso.org/standard/80585.html.
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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