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ISO 22301 guide

Ransomware recovery plan: how to build one with ISO 22301

How to build a ransomware recovery plan on the ISO 22301 chain: recovery priorities and data-loss limits from the BIA, a clean restore order, decisions settled before the attack, and exercises that prove the plan works.

  • Updated September 2026
  • 8-minute read
  • Part of the ISO 22301 hub

Key points

  • A ransomware recovery plan built with ISO 22301 starts from the business impact analysis: which activities must resume first, within what time frame, and how much data the business can afford to lose, before anyone decides what to restore.
  • Ransomware differs from a fire or a power cut because the recovery tools themselves may be compromised: backups, identity services and administrator accounts all need to be proven clean before they are trusted.
  • The hardest decisions (who isolates systems, who talks to clients, regulators and insurers, who decides on a ransom demand) belong in the response structure and communication procedures, agreed before the attack.
  • Only an exercise on a realistic ransomware scenario, followed by an evaluation that changes the plan, shows an auditor or a client that recovery will work.

What should a ransomware recovery plan do?

A ransomware recovery plan answers one question: when systems are encrypted and the attackers may still be inside, how does the organisation keep delivering its most important services and recover without reinfecting itself? Many plans called "ransomware recovery" are really IT restore runbooks: useful, but silent on which service comes back first, how much lost data the business accepts and what people do by hand meanwhile.

ISO 22301 supplies the missing part. Its clause 8 chain (business impact analysis and risk assessment, strategies and solutions, plans and procedures, exercise programme, evaluation) turns a technical restore into a business recovery. A ransomware plan written this way is not a separate document competing with the continuity plan; it is the continuity plan applied to one of the most likely scenarios an organisation now faces.

Why ransomware breaks ordinary recovery assumptions

Most continuity plans assume loss of a site, a supplier or a utility, with the systems intact. Ransomware reverses that: the building and the people are fine, and the systems are the problem.

  • The backups may be affected. A backup reachable with the same administrator credentials as production cannot be assumed to survive.
  • The last good copy is not the latest copy. If intruders were present for weeks, recent backups may contain their tools.
  • Identity services go down with everything else. When the directory service is encrypted, nobody can sign in to the systems needed for the restore.
  • Investigation and recovery compete. Investigators want affected systems preserved; the business wants them rebuilt.
  • Disruption lasts longer. Rebuilding from clean sources is slower than failing over to a standby site.
  • Data may have left the building. Where information was copied out, the incident also carries data protection notification duties.

Each belongs in the risk assessment under clause 8.2.3 and should lead to a decision under clause 8.3.

Building the plan on the ISO 22301 chain

The clause titles below are those of ISO 22301:2019; the ransomware questions are Sterling's recommended way of applying them.

ISO 22301 requirementThe ransomware questionThe record that answers it
8.2.2 Business impact analysisWhich activities must resume first, how long can each stop, and how much data can each afford to lose?BIA with a recovery time objective and a recovery point objective per prioritised activity, and the applications and data each depends on
8.2.3 Risk assessmentWhat would let encryption reach backups, identity services and critical applications, and how long would a clean rebuild take?Risk assessment of the ransomware scenario covering backup exposure, privileged access and third-party connections
8.3 Strategies and solutionsHow will the business operate while systems are down, and what guarantees a clean copy to restore from?Selection record for protected backups, clean rebuild capacity, manual workarounds and alternative tools, with costs and owners
8.4.2 Response structureWho declares the incident, who may isolate systems, and who decides on a ransom demand?Response team roles with named deputies, authorities and escalation thresholds
8.4.3 Warning and communicationHow will staff, clients, regulators, insurers and the media be told, if e-mail and chat are down?Out-of-band contact lists, pre-approved message templates and a notification log
8.4.4 and 8.4.5 Plans and recoveryIn what order are systems rebuilt, validated and returned to users?Recovery sequence tied to the BIA, validation checks before reconnection, and the return-to-normal steps
8.5 and 8.6 Exercise and evaluationDoes the plan work under pressure, and what changed afterwards?Tabletop and restore test reports, actions and the revised plan

Where the organisation also runs ISO/IEC 27001, the technical controls for backup, incident management and ICT readiness sit in that system, and the two share one BIA. The guide on ISO 22301 and ISO/IEC 27001 as one system explains how.

Setting the recovery order: time frames, data loss and the clean restore

The guide on running a business impact analysis covers the method; for ransomware, three outputs matter most. The recovery time objective tells IT what to rebuild first. The recovery point objective tells IT how far back it may reach for a clean copy, and therefore how often backups must be taken and how long they must be kept. The dependency list shows the hidden systems, such as directory services and name resolution, that must return first.

A worked example

Consider a BPO in the Philippines running payroll and customer-service work for three overseas clients. Its BIA finds that client voice services can stop for only a few hours before contractual penalties begin, payroll for two days if no pay run is due, and internal reporting for a week. All three rely on the directory service, so the recovery order starts with the foundations.

Recovery tierWhat comes backWhy in this order
Tier 0: foundationsA clean directory service, privileged access, name resolution and the backup platform itself, rebuilt in an isolated environmentNothing else can be restored or signed in to without them
Tier 1: shortest time frameTelephony, the customer-service platform and workforce management for the client voice servicesThe BIA gives them the shortest tolerable stop, and contracts attach penalties
Tier 2: next priorityPayroll application and its data, restored to a point confirmed as cleanA longer tolerable stop, but a fixed deadline on the pay date
Tier 3: can waitReporting, intranet, archives and development systemsManual workarounds cover them; restoring early adds risk and effort

Every tier passes a validation step before users reconnect: the restored system is scanned, access is checked and the data is compared against the last known good state. Manual workarounds for Tier 1, such as paper call sheets and client escalation numbers held off the network, keep the service alive while Tier 0 is rebuilt.

Decisions to settle before the attack

In a ransomware incident, undecided questions cause more delay than technology. The response structure required by clause 8.4.2 should settle them in advance:

  • Authority to isolate. Who can disconnect a site, a network segment or a cloud tenancy without waiting for a meeting, and on what evidence.
  • Investigation versus rebuild. Which systems are preserved for investigation, which are rebuilt immediately, and who breaks a tie.
  • The ransom demand. Who decides, who is consulted (legal counsel, the insurer, law enforcement where appropriate) and what the organisation's position is before any demand arrives.
  • Notifications. Which regulators, clients and data subjects must be told, within what period, and who owns each notification. The register of obligations under clause 4.2 is the source.
  • External support. The incident response provider, forensic support and insurer contact points, with how to reach them when corporate e-mail is down.

Under clause 8.4.3, contact lists, message templates and a meeting bridge must not depend on the corporate network.

How Sterling builds ransomware recovery

One BCMS, with ransomware as a planned scenario rather than an afterthought

Sterling's expert and experienced consultants run the BIA with your process owners, work through the ransomware scenario with IT and security, help management choose the solutions, write the response structure and recovery sequence with the people who will use them, and facilitate the first ransomware tabletop, with every record held in Effivity. Sterling does not certify; an accredited certification body audits your BCMS and decides. We ensure successful certification for our clients.

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Exercising the ransomware scenario

Clause 8.5 requires exercises on appropriate scenarios with defined aims. The guide on business continuity exercises sets out the formats; for ransomware, two exercises give the most evidence. A tabletop with management tests decisions: the moment of declaration, isolation, the ransom question, the first client message and the regulator clock. A restore test tests the technology: rebuilding a directory service and one Tier 1 application from protected backups, in isolation, timed against the recovery time objective.

Useful injects include encrypted backups, a client asking whether its data was taken, and intruders found to have been present for a month. The post-exercise report should record what took longer than planned, and clause 8.6 then requires the BIA, solutions and plans to be revised where the exercise exposed a weakness.

Where ransomware recovery plans fail

  • Backups tested for existence, not restorability. A green backup console does not show that an application can be rebuilt in time.
  • No foundation tier. Plans list business applications but forget the directory service and privileged access that every restore depends on.
  • A plan stored on the network it protects. If the only copy of the plan and the contact list is on the encrypted file share, the plan does not exist on the day.
  • No manual workaround. The business assumes IT will restore quickly and has never agreed how to operate for several days without systems.
  • Suppliers left out. Managed service and cloud providers' recovery commitments were never compared with the BIA's time frames.

Ransomware recovery planning with ISO 22301: questions buyers ask

What should a ransomware recovery plan include?

A ransomware recovery plan should include recovery priorities and time frames from the business impact analysis, the acceptable data loss per activity, a recovery order that starts with foundation systems, validation checks before reconnection, manual workarounds, clear authorities, out-of-band communication and exercise records.

Is a ransomware recovery plan the same as a disaster recovery plan?

No. A disaster recovery plan restores ICT systems; a ransomware recovery plan built with ISO 22301 also decides which services the business needs first, how it operates while systems are down, who takes the decisions and how clients and regulators are informed.

How often should a ransomware recovery plan be tested?

At planned intervals set in your exercise programme, and again after major changes to systems, suppliers or the threat. ISO 22301 does not fix a frequency.

Does ISO 22301 tell us whether to pay a ransom?

No. ISO 22301 requires a response structure with defined roles and authorities, but it does not take a position on payment. The organisation decides its approach in advance, with legal advice, its insurer and the guidance of the national cyber agency in each country where it operates.

How long does it take to build a ransomware recovery plan under ISO 22301?

Writing the plan takes weeks once the BIA exists. A full ISO 22301 programme typically runs four to eight months, and the ransomware scenario is built into it rather than added afterwards.

ISO 22301 implementation

ISO 22301 requirements

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