Do you need code review reviews for compliance?

If you’re a company aiming for ISO 27001 certification or a SOC 2 audit, you’ve probably asked yourself whever you needed to implement formal code reviews on every pull request.

Both frameworks avoid making direct mandates like “you must perform code reviews”, which creates ambiguity. However, code reviews are one of the clearest, most effective ways to show auditors that your development process is controlled.

Whether you’re navigating ISO 27001’s secure coding requirements or SOC 2’s change management criteria, a well-defined code review process can allow you to avoid some scrutiny.

Key takeaways

• Not explicitly required, but expected: Neither ISO 27001 nor SOC 2 explicitly names “code review” as a control, but both expect secure coding and change management to be enforced and verifiable.
• Code reviews are clear evidence: A formal, documented code review process is one of the most trusted ways to prove compliance with secure development and change control expectations.
• Simple process, big impact: A lightweight pull request workflow with approvals in GitHub or GitLab can satisfy most auditor requirements and improve code quality and security along the way.

Why code reviews matter for ISO 27001

ISO 27001:2022 includes Annex A Control 8.28 – Secure Coding, which requires organizations to:

“Establish and apply secure coding principles to software development.”

But the standard doesn’t say how to prove it. That’s where code reviews come in.

What ISO 27001 auditors expect

Auditors don’t just want to see that you’ve documented secure coding principles, they want to see that your team follows them in practice. That’s what Control A.8.28 is really testing.

The most compelling evidence? A code review process that demonstrates:

• Secure practices are applied to every code change.
• Issues are identified and discussed during reviews.
• No sensitive data (like secrets or keys) is accidentally introduced.
• Reviews are recorded and traceable in your version control system.

In other words: code reviews are your audit trail.

Why Code Reviews Matter for SOC 2

SOC 2 doesn’t list specific controls, it’s a principles-based framework. But one of its core criteria (CC8: Change Management) requires you to:

“Authorize, test, and approve changes before they are deployed.”

What SOC 2 auditors expect

From the auditor’s perspective, a code review process demonstrates:

• Documentation: every change is tracked in a pull request.
• Separation of duties: changes are reviewed and approved by someone other than the author.
• Evidence of control: approvals, comments, and merge histories provide a tamper-evident record of oversight.

A consistent code review process gives auditors confidence that your controls are designed properly and operating effectively.

What can a simple and efficient process look like

Regardless of framework, a few elements go a long way:

• A written policy explaining how code is reviewed, who reviews it, and what reviewers check for.
• A pull request workflow requiring at least one approval before merging.
• A changelog or audit trail** with timestamps, reviewer comments, and approval records (Github and cie provide this out of the box).

What if you’re a small team?

Even if you’re just a few engineers (or solo), some form of oversight is still expected.

Here’s how small teams can meet the requirement:

• Formal testing: changes are tested in a non production environment before merge.
• Automated controls: CI/CD pipelines to enforce checks and block risky changes.
• Review big releases: focus reviews on big changes and features.

The key is to show intent and structure, even if the process is lightweight.

Conclusion

Code reviews are not be explicitly required, but they’re functionally essential. They’re the single most effective way to demonstrate that secure development and change management controls are real, not just theoretical.

By implementing a formal code review process, you’re:

• Meeting ISO 27001’s secure coding requirements.
• Satisfying SOC 2’s change control expectations.
• Improving code quality and reducing bugs.
• Building a more secure and resilient product.

Frequently Asked Questions

1. What if we’re a very small team? Auditors still expect oversight. If you can’t separate duties, make sure you do proper testing before going to production.

2. What do auditors look for in code reviews? Not code quality. They want to see:

• Pull requests were created.
• Reviews were done by someone other than the author.
• Formal approval was given.
• The code was merged only after approval.

3. How formal does our process need to be? Not overly. Simplicity wins. A consistently followed pull request process with approvals is usually enough.