Do we need to implement all the controls from Statement of Applicability for the certification? Any idea regarding the percentage of status of the controls in the SoA that can be “planned”, “partially” or “implemented"?
Answer: You can leave some of the controls for the implementation for after the certification under the following conditions:
1) That you have implemented before the certification the controls that mitigate the biggest risks - in other words, you can leave only less important controls for after the certification.
2) That you have specified the deadlines for the controls that you will be implementing after the certification in your Risk Treatment Plan - of course, those deadlines must be after the certification date.
3) That your risk owners or top management accept all the risks for which controls have not been implemented before the certification.
This means that the most important controls must have "implemented" status at the certification, while the less important controls can have status "planned" or "partially i mplemented" at the moment of the certification.