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Information Security Management · Annex A · Statement of Applicability

ISO 27001 evidence as a continuous stream — not a quarterly screenshot collection.

ISO 27001 certifies the existence of an Information Security Management System. The evidence supporting that certification traditionally arrives as documents, screenshots, and self-attestation. H33 replaces that pile with a continuous stream of cryptographic receipts — every control firing, every policy change, every privileged action — independently verifiable by your assessor without trusting H33.

The auditor problem ISO 27001 doesn't solve on its own

Certification is periodic. Reality is continuous.

An ISO 27001 certification audit looks at the ISMS at moments in time: the initial Stage 1 and Stage 2 audits, the annual surveillance audits, and the recertification at year three. Between those moments, the organization is trusted to operate the controls it claims. The evidence the auditor reviews — policies, procedures, control records — is almost always self-generated and self-attested.

This is the gap. Self-attestation does not survive contact with adversarial scrutiny in 2026. Insurance carriers, enterprise customers, financial regulators, and increasingly the certification bodies themselves want evidence that the controls actually fired, in the order claimed, against the policy in force at the time — without trusting the organization to be honest about it.

H33 fills that gap. The ISMS that runs on H33 produces, at runtime, a continuous stream of independently verifiable receipts. The Statement of Applicability stops being a document the auditor reads. It becomes a verifier the auditor runs.

How H33 maps to ISO 27001:2022 Annex A

The 4 themes, the 93 controls, the H33 layer underneath.

ISO 27001:2022 organizes Annex A into four themes — Organizational (37), People (8), Physical (14), and Technological (34). H33 does not replace any of these. It makes the technological and organizational controls generate evidence in a form your assessor can independently verify.

Organizational controls (5.x)

Policies, roles, classification, supplier relationships, threat intelligence. H33 binds each policy version to a signed identifier; every control decision references the policy version in force at the time. Future assessors verify against the policy that existed, not the current one.

People controls (6.x)

Screening, terms of employment, awareness, disciplinary actions. Authorization events tied to a person (and the role they held at the time) emit receipts via Agent-008. Role changes, suspensions, and revocations are themselves recorded as policy events.

Physical controls (7.x)

For environments under H33 governance, physical access events from badge systems are receipt-bound; cryptographic receipts attest the time, location, and authorization state.

Technological controls (8.x)

The largest theme and where H33 carries most of the load. Identity, access management, secrets, logging, monitoring, cryptography, network security, software development, and supplier security — all 34 controls have H33 evidence patterns.

Specific controls with H33 patterns

Selected Annex A controls and the H33 evidence layer.

ControlH33 evidence
5.7 Threat intelligenceThreat-feed ingestion events emit receipts: source, payload hash, processing rule, action taken
5.15 Access controlEvery access decision (allow / deny / step-up) carries a receipt with policy version, identity, resource, decision rationale
5.16 Identity managementIdentity lifecycle events (create, modify, suspend, delete) emit receipts; complete chain replayable
5.17 Authentication informationH33-Key receipts attest every credential use without disclosing the credential itself
5.23 Information security for cloud servicesConfiguration drift, control changes, and security posture changes against cloud services receipt-bound and replayable
8.2 Privileged access rightsPrivileged-action receipts include the elevation justification, expiry, and the policy version that authorized it
8.5 Secure authenticationAuthentication events receipt-bound; post-quantum signatures for long-retention authentication records
8.15 LoggingLogs become receipts. The integrity of a log entry is verifiable independently — not "we trust the logger"
8.16 Monitoring activitiesDetection events and the rules that produced them are receipt-bound and replayable against the same inputs
8.24 Use of cryptographyCryptographic key use, rotation, and revocation events emit receipts; cryptographic agility supported via Q-Sign three-family signatures
8.32 Change managementCode changes, configuration changes, policy changes — each a receipt with author, approver, justification, policy version
H33 products that carry ISO 27001 evidence

The substrate components.

Continuous Attestation

HATS

The continuous-evidence layer. Replaces sampling with a stream the auditor verifies independently.

Decision Integrity

Agent-008

For automated systems making access, authorization, or policy decisions. Every decision carries a receipt.

Secrets Governance

H33-Key

Authentication information (A.5.17, A.8.5) governed without disclosure. Every secret use receipt-bound.

Portable Evidence

H33-74

The 74-byte receipt format. Long-retention records that survive cryptographic transitions.

Cryptographic Agility

Q-Sign

Three-family signatures supporting A.8.24 cryptographic agility. Ready when NIST transitions.

Compliance Signal

PQ Verified

Demonstrate cryptographic compliance to assessors and customers without requiring them to trust your word.

What the assessor sees

The continuous-evidence advantage.

An ISMS that uses H33 for its evidence layer gives the assessor a fundamentally different surface to review. The Statement of Applicability points at controls that produce a continuous stream of receipts. The assessor's role shifts from asking the organization for evidence to verifying the evidence themselves.

Bring continuous-evidence to your ISO 27001 program.

H33 is currently in audit under Drata. Talk to us about how the substrate maps to your Statement of Applicability.

Talk to H33 How HATS works