ASD ISM guide

The ISM in plain English: what changed in September 2026, and whether it applies to you.

ASD published the September 2026 Information Security Manual on 7 September. It has 44 new controls, and two of them are about how your IT provider is allowed to connect to your systems. Most businesses are not legally required to follow the ISM, but the new controls are some of the most practical ASD has written for anyone running Microsoft 365.

Counts checked against ASD's ISM catalogue on 30 October 2026.

  • 49 principles, 1,143 controls
  • 44 new controls
  • All 44 apply to non-classified systems

Reviewed by Blake Bath, General Manager, on 30 October 2026.

A man in a navy polo points at a spiral-bound manual with coloured tabs while a woman with a laptop listens, in front of a whiteboard covered in a hand-drawn flowchart.
Published 7 September 2026Current ISM release on cyber.gov.au.

Does the ISM apply to you?

Four questions before you read 1,143 controls.

The ISM is a framework, not a law. Whether you need it depends on who you work for and what information you hold.

Does a law or direction require it?

ASD says an organisation is not required by law to comply with the ISM unless legislation, a direction under legislation or another lawful authority compels it. The ISM also does not override any law.

  • Not a legal requirement on its own
  • Law wins if the two conflict
  • Privacy and SOCI obligations still apply separately

New controls self-check

How many of the September 2026 controls do you already meet?

Ten of the 44 new controls that matter most for a small or mid-sized business. Tick what is true today and copy the gaps for your IT provider.

Ten of the 44 new controls from the September 2026 ISM. Tick what is true at your business today.

Where you stand

0of 10 controls in place

10 gaps to close.

  • Your MSP can only connect through tools, addresses and times you approvedNew in September 2026. Service provider access is limited to approved remote tools, source addresses and time windows.
  • You keep your own log of your MSP's access, which they cannot changeThe log has to be yours and analysed in a timely way, not a report your provider sends you.
  • You have a list of approved remote access and RMM tools, and others are blockedAttackers use legitimate remote support tools. Unapproved ones should be blocked at the gateway.
  • Bank detail and account changes are confirmed through a known channelA voice or video request can now be faked. Confirm on a number or channel you already trust.
  • Staff cannot approve third-party apps into Microsoft 365 or GoogleOnly an admin grants app consent, and consents are reviewed at least every six months.
  • Device code sign-in is blocked unless you need itDevice code phishing tricks people into signing an attacker in on a real Microsoft page.
  • Sessions and tokens are revoked when a password is reset or an account is suspectedResetting a password does not help if the attacker's session stays alive.
  • Backups cannot be changed or deleted during their retention periodImmutable backups, on infrastructure separated from production with separate admin sign-in.
  • You keep a register of AI agents with their own identitiesEach agent gets its own identity, owner, purpose and a record of what it can access.
  • Network gear is managed only from a separate management networkManagement interfaces should not be reachable from the user network or the internet.
Talk to an engineer

What changed in September 2026

The 44 new controls, by topic.

We compared ASD's machine-readable ISM catalogues for June 2026 (v2026.06.18) and September 2026 (v2026.09.4). These are the control IDs that are new. Two June controls, ISM-0521 on IPv6 and ISM-1448 on TLS configuration, are no longer listed.

TopicNew controlsWhat it asks
Access by service providers2MSP access limited to approved tools, addresses and times, and logged by you
Administrative tools2A list of approved RMM and remote access tools; others blocked at the gateway
Synthetic impersonation1Confirm account, bank detail and payment requests through a trusted channel
Third-party apps and device code sign-in4Admin-only app consent, six-monthly consent reviews, logging, device code flow off
Tokens and sessions2Tokens bound to the device; sessions revoked on reset or compromise
Application and workload credentials6Short-lived, unique, centrally managed secrets, changed and revoked properly
Authentication1Risk-based access decisions using contextual signals
AI agents7Unique agent identities, an agent register, least privilege, untrusted content handling, logging
Backups2Immutable for the retention period; backup systems segregated with separate admin sign-in
Threat hunting1Threat hunting informed by threat intelligence at least every three months
Windows hardening3Signed drivers enforced, kernel code limited, WMI activity logged centrally
Active Directory Certificate Services3Web enrolment locked down, templates reviewed every three months, events logged
Network devices3Separate management network, firmware integrity, unneeded features off
MACsec5Settings for wired network encryption where MACsec is used
Software development2Pinned dependencies and reproducible builds

Counts from ASD's ISM OSCAL catalogues, compared on 30 October 2026. ASD also publishes a change summary PDF with the September release.

Our view

Two of the new controls are about us, and we think they are right.

ISM-2124 says a service provider's access is restricted to remote management tools, source network addresses and time windows the organisation has explicitly approved. ISM-2125 says all of that access is logged by the organisation, in a way the provider cannot change or delete, and analysed quickly.

For an MSP, that is a fair standard. Your provider holds some of the most powerful access in your business. You should know which tools they use, be able to see every session, and own the log. ISM-2149 and ISM-2150 go with them: keep a list of approved RMM and remote access tools, and block the rest at the gateway, because attackers like to use legitimate remote support software.

If you use an MSP, ask them three things: which remote tools they use on your systems, where their connections come from, and where you can see a log of their access that they cannot edit. That includes asking us.

Identity controls

The identity controls you can switch on in Microsoft 365.

Several new controls map directly to settings in Microsoft Entra ID. Conditional Access needs Entra ID P1, which comes with Business Premium.

  • Admin-only app consent (ISM-2137)

    Turn off user consent to third-party apps so only an administrator can approve them. Then review existing consents at least every six months (ISM-2138).

  • Block device code flow (ISM-2140)

    Microsoft recommends blocking device code flow wherever possible, using a Conditional Access authentication flows policy. Teams Rooms and some shared devices need a scoped exception.

  • Revoke sessions on reset (ISM-2148)

    When a password is reset or an account looks compromised, revoke its sessions and refresh tokens too, or the attacker stays signed in.

  • Risk-based access (ISM-2136)

    Access decisions use signals such as location, device compliance and sign-in risk. Sign-in risk policies need Entra ID P2.

AI agents

AI agents now need identities, a register and limits.

Seven new controls cover AI agents and agentic AI applications, alongside the GOV-08 principle that the board or executive is accountable for AI being secure, controllable and human-supervised.

  • A unique identity for every agentSeparate from staff accounts and from other agents (ISM-2133).
  • An AI agent registerEach agent's identifier, owner, business purpose, identities, credentials, and the tools, permissions and data it can reach (ISM-2134, ISM-2135).
  • Least privilegeAgents get only the tools and permissions their purpose needs, checked against both the user's and the agent's own access (ISM-2156, ISM-2157).
  • Outside content stays untrustedWeb pages and documents an agent reads are treated as untrusted data, kept apart from its instructions (ISM-2158).
  • Everything loggedTool calls, external requests and outputs are logged (ISM-2159).

How the ISM is used

ASD's six steps, in order.

From ASD's Using the cyber security framework chapter.

  • Define the systemBoundary, business criticality, and security and resilience objectives, written into a system security plan.
  • Select security controlsChoose and tailor controls using their applicability markings and your risks. Record them in the system security plan annex.
  • Implement security controlsPut them in place, and record any differences from the plan.
  • Assess security controlsCheck they are in place and working, by your own assessors or IRAP assessors, depending on the classification.
  • Authorise the systemThe authorising officer decides whether the remaining risk is acceptable.
  • Monitor the systemKeep checking controls, threats and changes, and go back a step when something material changes.

ISM, Essentials, SMB1001

Where the ISM sits next to the frameworks you hear about.

FrameworkWhat it isBest for
ASD ISMASD's full framework: 49 principles and 1,143 controls, selected per systemGovernment systems and contracts that name it
ASD EssentialsASD's new baseline published in October 2026, replacing the Essential Eight over timeMost businesses wanting ASD's priorities
Essential EightEight mitigation strategies with maturity levels; still current while the Essentials transition is setExisting programs and contracts that name it
SMB1001A tiered certification standard for smaller businesses, from Dynamic Standards InternationalShowing clients and insurers a certified level

Mistakes we see

Five ways businesses get the ISM wrong.

  • Assuming government work makes you PROTECTEDThe classification of the information sets the controls, not the customer's name.
  • Treating an assessment as approvalThe assessor reports. The authorising officer decides.
  • Implementing everything1,143 controls are a catalogue to select from, not a to-do list.
  • Ignoring the MSP controlsYour provider's access is in scope. Ask how they meet ISM-2124 and ISM-2125.
  • Evidence that is a screenshot from day oneAssessors want to see controls still working: logs, reviews and restore tests.

How we help

Control mapping and evidence, priced by the hour.

We map your Microsoft 365, devices and network against the controls a contract asks for, set up what is missing and keep the evidence. We quote at our published rate of $195 an hour ex GST. Independent assessment and authorisation are separate: an assessor checks, and your authorising officer decides.

How we work through it

From contract clause to evidence, in five steps.

  1. Step 1Read the requirement

    Which ISM release, classification and baseline your contract or customer names.

  2. Step 2Draw the boundary

    Tenants, devices, networks, people and suppliers in scope.

  3. Step 3Map the controls

    Each applicable control marked as in place, inherited from a supplier, or a gap.

  4. Step 4Close the gaps

    Settings changed, processes written, and new controls like MSP access logging put in place.

  5. Step 5Keep the evidence

    Logs, reviews and restore tests kept with the control, ready for an assessor.

Questions

What people ask about the ISM.

Is the ISM mandatory for Australian businesses?

No, not as a matter of law. ASD says an organisation is not required to comply with the ISM unless legislation, a direction given under legislation or another lawful authority requires it. A government contract or agency can require it, and then you meet what the contract specifies.

What changed in the September 2026 ISM?

ASD published it on 7 September 2026. Comparing ASD's machine-readable catalogues, it has 44 controls that were not in the June 2026 release, and 2 June controls are no longer listed. The new controls cover service provider access, RMM tools, OAuth app consent and device code sign-in, tokens and sessions, application credentials, AI agents, immutable backups, threat hunting, network device management and MACsec.

How many controls are in the ISM?

The September 2026 catalogue has 49 cyber security principles and 1,143 controls. Of those controls, 1,017 are marked as applying to non-classified systems.

What do NC, OS, P, S and TS mean?

They are applicability markings: non-classified, OFFICIAL: Sensitive, PROTECTED, SECRET and TOP SECRET. Each control shows which kinds of system it applies to. All 44 new controls in the September 2026 release apply to non-classified systems as well.

Does an IRAP assessment certify our system?

No. An assessment checks whether controls are in place and working, and its report goes to the authorising officer, who decides whether to accept the remaining risk and authorise the system. For non-classified, OFFICIAL: Sensitive, PROTECTED and SECRET systems, ASD says assessments can be done by the organisation's own assessors or IRAP assessors.

Should a small business use the ISM or the ASD Essentials?

Unless a contract names the ISM, most small businesses get more from the ASD Essentials and a standard like SMB1001. The ISM is the deeper reference. The new controls are still worth reading, because several of them, like blocking device code sign-in and locking down MSP access, are cheap to do in Microsoft 365.

Next step

Has a contract asked you for the ISM?

Send us the security schedule. An engineer will tell you which controls apply, what you already meet and what it will take to close the rest.

Chip, the Real Bytes support assistant

Keep reading

Reviewed by Blake Bath, General Manager, on 30 October 2026. Control wording and counts from ASD's ISM OSCAL catalogues (September and June 2026). Legal standing, applicability markings, the six steps and assessments from ASD's Using the cyber security framework. Device code guidance from Microsoft Learn. ASD, Information security manual (September 2026); ASD, Using the cyber security framework (September 2026); ASD, Cyber security principles (September 2026); ASD, ISM OSCAL v2026.09.4; Microsoft Learn, Block authentication flows with Conditional Access