CISO × ISO 27001 ISMS Consulting & Certification

CISO implementing ISO 27001: board reporting, the ESG bonus point and certification scope

Updated 2026-11-03

Short answer

For a CISO, ISO 27001 is the backbone for answering corporate governance requirements: under Article 9-1 of the internal control regulations every public company must plan, monitor and carry out information security management; the annual report must disclose cybersecurity management; and indicator S-12 of the TWSE ESG evaluation adds one point overall for ISO 27001 with third-party certification. Implement ISO/IEC 27001:2022; the service page lists a typical 4–8 months. Companies that are not public companies are not covered by these rules and can use them voluntarily.

Which corporate governance requirements can ISO 27001 help a CISO answer?

RuleWhat it asks of the CISO
Regulations Governing Establishment of Internal Control Systems by Public Companies, Article 9-1Allocate adequate staff and equipment to plan, monitor and carry out information security management
TWSE and TPEx Cybersecurity Control Guidelines for Listed CompaniesDedicated head (Art. 3), incident response and reporting (Art. 34), reporting to the board or management (Art. 37), security audits (Art. 38)
Regulations Governing Information to be Published in Annual Reports of Public Companies, Article 18, item 6Disclose the cybersecurity risk management framework, policy, concrete programmes and resources invested

A CISO can answer several of them with one body of risk assessment, incident response, supplier management and audit evidence, and ISO 27001 is the backbone of that evidence. Under Article 41 of the guidelines, listed companies may adopt them as appropriate to their industry, size and cybersecurity risk; companies that are not public companies are not covered by these rules and can use them voluntarily.

How does ISO 27001 certification help with indicator S-12 of the TWSE ESG evaluation?

The ESG evaluation replaced the corporate governance evaluation from 2026 and covers listed companies. S-12 asks whether the company has built and disclosed a cybersecurity risk management framework, policy, concrete programmes and the resources invested, and it is assessed from the annual report.

  • Bonus condition: implementing ISO 27001, CNS 27001 or another information security management system standard, or an equivalent or stronger system or standard, with third-party certification, adds one point overall.
  • Third-party certification is what counts: declaring that you have implemented the standard, without certification, does not meet the bonus condition.
  • Editions: the wording is the same in the 2026 and 2027 indicators.

Other indicators in the CISO's remit are S-13 (personal data protection policy) and S-15 (supplier management policy, including information and communication security).

How do we set the certification scope? Do all 93 controls have to be implemented?

First determine the certification scope required by customers, tenders and regulators, then carry out the risk assessment.

  • Not all 93 controls are required: the risk assessment decides applicability, which is recorded in the Statement of Applicability (SoA); excluded controls need a stated reason.
  • Where auditors look: auditors and customer due diligence look closely at the consistency of the risk assessment method and the soundness of the SoA.
  • Version: always implement ISO/IEC 27001:2022; the transition period for 2013 certificates ended on 31 October 2025. Organisations with a system built on the old version do not start over; they map controls and close the gaps.

When the CISO reports to the board, which ISO 27001 outputs can be used directly?

Article 37 of the Cybersecurity Control Guidelines requires regular reporting on cybersecurity to the board or management, without setting a frequency; banks and financial holding companies follow Article 24 of their implementation rules, under which the chief information security officer reports to the board each year on the previous year's information security.

Records that an operating ISO 27001 system keeps producing can feed the report:

  • Risk assessment results and the SoA
  • Internal audit findings and corrective action tracking
  • Management review conclusions

Put the applicability decisions, reporting drills and audit results for all requirements into one report rather than writing separate ones. Companies that are not public companies are not covered by the guidelines and can use them voluntarily.

Our dedicated security staff is small. Can the ISO 27001 internal audit be outsourced?

Yes. ISO 19011:2018 defines an internal audit as one conducted by, or on behalf of, the organisation itself. There is one hard limit: under clause 5.2.6 of ISO/IEC 17021-1, a certification body may not carry out internal audits for its own certification clients, so you outsource to a consultant, not to your certification body.

For staffing, the FSC order of 28 December 2021 is a reference: listed companies meeting its conditions must set up a dedicated unit with a head and at least two dedicated staff; other listed companies (with the exceptions in the order) must have a dedicated head and at least one dedicated staff member. Article 38 of the guidelines also calls for regular internal and vendor security audits. Before outsourcing, check that the person actually doing the audit holds a lead auditor qualification and is independent.

How long does ISO 27001 take, and how much time does it save for NIS2, 27701, 22301 and 42001?

The service page lists a typical 4–8 months: gap analysis, system build, internal audit and management review, then stage 1 and stage 2 certification audits; an existing IT governance base shortens this noticeably.

27001 is the shared backbone for what comes next. The times listed on each service page:

Next requirementTime listed on the service page
NIS2Usually 4–6 months; 2–3 months with 27001
ISO 277015–8 months for integrated certification; 3–5 months with 27001
ISO 22301Usually 4–7 months; about 3–5 months with 27001
ISO 42001About 6–9 months from scratch; usually 4–6 months with 27001

How does Winners Consulting help a CISO with ISO 27001?

  • Scope first: confirm the security requirements of customers, tenders and regulators, and set the certification scope.
  • One risk language: build the assessment framework in ERM risk language so the 27001 risk register connects with the enterprise risk map.
  • One body of evidence: use ISO 27001 as the backbone so ISO 27701, 22301 and 42001 share the management system.
  • Outsourced internal audit: for certified organisations, Winners can carry out the internal audit.
  • Division of roles: Winners Consulting is a consultant and does not certify; VP- and director-level consultants lead the work end to end, never outsourced.
  • Named clients: MPI Corporation, InfoLight, Cho Yuan, Hypercore Fitness Center, the Joint Credit Information Center (JCIC) and the Taiwan Stock Exchange (TWSE).

Read more: ISO 27001 consulting, choosing an ISO 27001 consultant, outsourcing the ISO 27001 internal audit. Apply for a free mechanism diagnosis

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