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ISM-2038 policy ASD Information Security Manual (ISM)

Maintain Developer Cyber Security Skills Register

Keep a record of software developers' cybersecurity skills and knowledge.

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Plain language

This control is about keeping track of the cybersecurity skills and knowledge of the software developers in your organisation. This is important because if developers aren't up to speed on security, they might create software that is vulnerable to attacks, putting your business and customer data at risk.

Framework

ASD Information Security Manual (ISM)

Control effect

Proactive

Classifications

NC, OS, P, S, TS

ISM last updated

Nov 2025

Control Stack last updated

19 Mar 2026

E8 maturity levels

N/A

Official control statement

A software developer cyber security knowledge and skills register is implemented and maintained.
policy ASD Information Security Manual (ISM) ISM-2038
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Why it matters

Without a developer cyber security skills register, skills gaps go unnoticed, increasing the likelihood of insecure code and missed secure development practices.

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Operational notes

Maintain a central register of each developer’s cyber security skills, training and certifications, and review/update it after courses, onboarding and role changes.

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Implementation tips

  • HR should work with IT to create a cybersecurity skills register: This means listing all the developers and noting down their specific skills and any formal cybersecurity training they have completed.
  • IT managers should regularly update the skills register: Schedule a quarterly review to ensure that any new skills or training the developers have acquired are recorded.
  • Line managers should identify skill gaps and plan further training: They should review the register to spot any missing skills that are critical for security and organise relevant training sessions.
  • Developers should log self-directed learning activities: Encourage developers to write down any workshops or certifications they complete independently and share these with their managers.
  • Organisational leaders should review the skills register annually: A senior leader should sign off on the register each year to ensure that the organisation is maintaining strong cybersecurity capabilities.
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Audit / evidence tips

  • AskThe cybersecurity skills register: Request the document that lists developers' skills and training records GoodShows a regularly updated register with relevant skill entries for each developer
  • AskThe schedule of skills review meetings: Ensure there's a structured plan for regular updates to the register GoodIncludes a documented schedule showing consistent updates
  • AskTraining plans for developers: Request any documented plans for developer training in cybersecurity GoodLinks the training to specific needs in the register
  • AskAbout self-directed learning submissions: Find out how developers report independent learning GoodIncludes records of developer-initiated learning being added to the register
  • AskThe annual review sign-off: Request evidence of a senior leader's review of the register GoodDemonstrates leadership oversight and commitment to cybersecurity training
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Cross-framework mappings

How ISM-2038 relates to controls across ISO/IEC 27001, ISO/IEC 42001, Essential Eight, and ASD ISM.

ISO 27001

Control Notes Details
handshake Supports (2) expand_less
Annex A 5.2 ISM-2038 requires organisations to implement and maintain a register of software developers’ cyber security knowledge and skills
Annex A 6.3 ISM-2038 requires organisations to implement and maintain a register of software developers’ cyber security knowledge and skills

ISO 42001

Control Notes Details
sync_alt Partially overlaps (1) expand_less
Annex A 4.6 Annex A 4.6 (ISO/IEC 42001:2023) requires the organisation to document AI-related human resources and their competencies across developme...

These mappings show relationships between controls across frameworks. They do not imply full equivalence or certification.

Mapping detail

Mapping

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Controls