CISO × ISO 22301 Business Continuity Management System Consulting

CISO guide to ISO 22301: ICT recovery, RTO and exercises

Updated 2026-11-03

Short answer

For a CISO, ISO 22301 is the certifiable management system that gives ICT backup and disaster recovery an RTO and RPO derived from a business impact analysis (BIA), plus exercise records; a BCP document alone is not enough, and a plan without a BIA and exercise records counts as non-existent in audits and customer reviews. It shares the Annex SL structure, and backup and ICT continuity documents, with ISO 27001. The service page lists four phases taking usually 4–7 months, about 3–5 months with 27001; the BIA and exercises cannot be compressed.

Who sets the RTO and RPO, and how far does the CISO's responsibility go?

The RTO is how soon you must recover; the RPO is how much data you can afford to lose. Both should be derived from the BIA's impact analysis and decided by management, then checked against current backup capability; if capability falls short, it becomes an investment decision.

A common mistake is drawing the target after shooting the arrow: copying an attractive RTO with no matching capability. The CISO's job is to connect recovery objectives to technical verification of backup and disaster recovery, so that budget proposals rest on the BIA and the capability gap.

We already have ISO 27001. What evidence can ISO 22301 share?

It can, and integration is recommended. Both use the Annex SL structure, and 27001 controls A.5.29/5.30 (security during disruption, ICT readiness) connect directly to 22301:

  • Backup and ICT continuity documents are shared with 27001
  • Integrated implementation shares documents and audits, at lower incremental cost than doing them separately
  • Exercise records serve as evidence for both certification and customer questionnaires

Timeline listed on the service page: about 3–5 months with 27001.

How often should we exercise, and what records should the CISO keep?

The standard requires exercises at planned intervals and after significant changes; the practical baseline is at least one full exercise a year plus scenario-based tabletop exercises. The review and improvement records after an exercise matter as much as the exercise itself. A BCP without exercise records counts as non-existent in audits and customer reviews.

Security scenarios can include ransomware: within the ISO 22301 framework, build a ransomware BCP chapter with an IT-DRP, a crisis communication SOP and a procedure for working with law enforcement, and exercise rebuilding all IT systems, not just partial recovery.

When a security incident disrupts operations, how does the continuity plan connect to statutory reporting deadlines?

One event may trigger several deadlines, each with its own starting point and receiving authority; first decide which regimes apply to the company:

RegulationDeadline
GDPRWithout undue delay and, where feasible, within 72 hours of awareness
NIS2Early warning in 24 hours, notification in 72 hours, final report within one month
DORAInitial notification within 4 hours of classifying as major and no later than 24 hours from awareness
EU CRAEarly warning in 24 hours, notification in 72 hours

The BCM reporting procedure should include how deadlines are counted, templates for authority notifications, risk-tiered notices to affected persons, and media and investor relations handling.

Can ISO 22301 carry customer questionnaires and NIS2 or DORA resilience requirements? Does the certificate equal compliance?

It can carry the evidence, but the certificate is not compliance. NIS2 business continuity measures, DORA ICT operational resilience and brand owners' supplier backup questions can all be answered from a 22301 system. But NIS2 and DORA have no standalone certificates, and an ISO certificate is not regulatory compliance; first determine whether the company is a covered entity, an EU financial entity, or a supplier to one.

Version: the current edition is ISO 22301:2019 with Amendment 1 of 2024 (organisations must determine whether climate change is a relevant issue); the third edition is still at committee draft stage with no publication date, so implementation today is still certified against the 2019 edition.

How should budget and timeline be planned, and which phases cannot be compressed?

The service page lists four phases taking usually 4–7 months, about 3–5 months with 27001:

PhaseTimeline
Scope and BIA4–6 weeks
Strategy and plans4–6 weeks
Exercises and revision4–8 weeks
Audit and certification3–6 weeks

The BIA and exercises cannot be compressed. Budget depends on the number of critical activities and sites in scope, how deep the BIA goes, and the current state of backup and disaster recovery. Certificates run on a 3-year cycle, with stage 1 and stage 2 audits by a third party.

How does Winners Consulting help a CISO with ISO 22301?

Winners Consulting's approach (test us with the questions above too):

  • VP- and director-level consultants lead in person; nothing is outsourced; consultants hold ISO 22301 lead auditor qualifications
  • Clause 8 at the core and ISO/TS 22317 for the BIA, sharing backup and ICT continuity documents with 27001
  • At least one tabletop and one functional exercise per project, plus an evidence pack for customer questionnaires
  • Certification is by a third party; Winners consults and does not certify

ISO 22301 business continuity, Choosing an ISO 22301 consultant, Budget and timeline. Apply for a free mechanism diagnosis

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