AACF
Cross-reference

ISO/IEC 42001

65 items: 48 met directly by a control at Level 3, 17 partly, 0 deliberately out of scope.

RefItem (our description)ControlsNote
4.1Understand the organisation's context and the issues that affect its AI aimsSTR-05 partial, STR-01 partialHorizon scanning and strategy alignment cover external and internal issues; no control asks for an explicit context analysis for AI governance.
4.2Identify interested parties and their requirementsSTR-07 direct, RSK-04 partial
4.3Define the scope of AI governanceGOV-01 direct, STR-02 partialGOV-01 Level 3 requires the policy to state what AI governance covers.
4.4Establish and run the AI management system as a wholeGOV-04 partial, MON-07 partialMet by operating the framework as a whole rather than by one control.
5.1Top management commitment and supportGOV-02 direct, STR-03 partial
5.2Set and communicate an AI policyGOV-01 direct
5.3Make clear who does what in AI governance, and with what authorityGOV-02 direct, GOV-05 direct, GOV-03 partial
6.1.1Address risks and opportunities; set AI risk criteriaRSK-01 direct, RSK-02 partial
6.1.2Assess AI risksRSK-02 direct
6.1.3Treat AI risks and justify the controls chosenRSK-02 direct, RSK-07 partialRSK-02 Level 3 requires the treatment and the controls applied to be recorded with reasons, which serves as the statement of applicability.
6.1.4Have a process for AI system impact assessmentRSK-03 direct
6.2Set measurable AI objectives and plan to achieve themSTR-01 direct, STR-06 partial, MON-01 partial
6.3Plan changes to the management system in a controlled waySTR-08 partialStrategy review covers changing direction; no control covers controlled change to the governance arrangements themselves.
7.1Provide the resources neededSTR-03 direct, OPM-01 partial
7.2Ensure competencePPL-04 direct, PPL-05 direct, PPL-03 partial
7.3Ensure awareness of the policy and of each person's part in itPPL-01 direct, CUL-02 partial
7.4Plan internal and external communicationCUL-02 direct, GOV-09 partial
7.5Keep governance records current, approved and findableGOV-01 direct, DAT-06 partialGOV-01 Level 3 requires governance documents to be approved, version-controlled and retained; DAT-06 covers AI records.
8.1Plan and control operational processesPOR-04 direct, GOV-03 partial, OPM-07 partial
8.2Carry out AI risk assessments at planned intervals and on changeRSK-02 direct, MON-05 partial
8.3Implement the risk treatment planRSK-02 direct, RSK-07 partialCovered through RSK-02's treatment record, as for 6.1.3.
8.4Assess the effects of each AI system on people and societyRSK-03 direct
9.1Check how well AI governance is working, using evidenceMON-01 direct, MON-02 direct, MON-03 partial
9.2Audit the management system internallyMON-05 direct, MON-07 partialMON-05 Level 3 requires the AI governance arrangements as a whole to be independently audited on a set cycle, with findings owned and tracked; MON-07 re-runs this assessment.
9.3Top management reviews the management systemMON-08 direct, GOV-04 partial
10.1Improve continuallyMON-07 direct, GOV-08 partial
10.2Fix failures to follow the system, and their causesGOV-08 partial, MON-04 partialExceptions and incidents are covered; no control requires root-cause analysis and corrective action for nonconformities generally.
A.2.2Document an AI policyGOV-01 direct
A.2.3Align the AI policy with other organisational policiesGOV-07 direct
A.2.4Review the AI policyGOV-01 direct
A.3.2Define and allocate AI roles and responsibilitiesGOV-05 direct, GOV-02 partial
A.3.3A route to report concerns about AICUL-04 direct
A.4.2Document the resources AI activities needGOV-06 partial, OPM-01 partial, STR-06 partialThe inventory records each use and links it to its models, data sets and integrations (GOV-06), and the roadmap names the capability, data and technology capacity planned uses depend on (STR-06); documenting the other resources per system and lifecycle stage (tooling, compute, people) is system-level detail.
A.4.3Document data resourcesGOV-06 direct, DAT-08 partial, DAT-04 partialGOV-06 Level 3 links each inventory entry to the data sets it uses, and DAT-08 records each data set's source, collection method, rights and use limits, so the data resources of each use are documented; DAT-04 catalogues meaning, coverage and limits.
A.4.4Document tooling resourcesTEC-01 partialTEC-01 lists approved tools, where AI is built in house, the environments and toolchains used to build, test and run it, each with an owner and support. Recording which tooling each system uses is system-level and not required.
A.4.5Document system and computing resourcesTEC-02 partial, TEC-03 partial, STR-06 partialArchitecture and hosting are governed (TEC-02, TEC-03), and the roadmap names the compute and storage capacity planned uses depend on (STR-06); per-system compute records are system-level.
A.4.6Document people and competences involvedPPL-04 partial, GOV-05 partialSkills are assessed by role (PPL-04) and owners are named (GOV-05); per-system records of the people and competences involved are system-level.
A.5.2A process to assess impacts on people and societyRSK-03 direct
A.5.3Document and retain impact assessment resultsRSK-03 partial, DAT-06 partialRSK-03 requires the assessment; keeping documented results for a defined period is implied, not explicit (DAT-06 covers AI records generally).
A.5.4Assess impacts on individuals and groupsRSK-03 direct, RSK-06 partial
A.5.5Weigh effects on society and the environmentRSK-03 directRSK-03 widened to societal and environmental effects.
A.6.1.2Goals that steer how AI is built responsiblyRSK-05 partial, OPM-06 partialAdopted principles (RSK-05) and delivery standards (OPM-06) guide development; documented objectives for responsible development are not explicit.
A.6.1.3Defined processes for responsible design and developmentOPM-06 direct, POR-04 partial
A.6.2.2Specify requirements for new or materially changed systemsPOR-05 partial, OPM-06 partialThe business case (POR-05) and delivery standards (OPM-06) capture the need; documented system requirements are system-level.
A.6.2.3Document design and developmentOPM-06 partial, TEC-05 partial, POR-04 partialDelivery standards and release control imply design records, and POR-04 keeps a record of key design decisions and assumptions for each use, updated at each gate; full design and development documentation for each system is system-level.
A.6.2.4Verification and validation measures and criteriaTEC-06 direct
A.6.2.5Deployment plan and pre-deployment requirementsPOR-04 partial, POR-07 partial, TEC-05 partialStage gates (POR-04), pilot-to-production criteria (POR-07) and release control (TEC-05) cover go-live; a documented deployment plan is not explicit.
A.6.2.6Operation and monitoring, repairs, updates and supportOPM-07 direct, MON-02 direct, TEC-05 partial
A.6.2.7Technical documentation for each kind of interested partyTEC-05 direct, RSK-08 partial, GOV-09 partialTEC-05 Level 3 requires documentation for each version suited to users, operators and regulators.
A.6.2.8Keep event logs, at least when in useMON-02 direct, DAT-06 partialMON-02 Level 3 requires event logging while in use.
A.7.2Data management processes for developmentDAT-01 direct, DAT-08 partial, DAT-02 partial, DAT-03 partialDAT-01 Level 3 backs the data strategy with an approved data architecture covering how data used by AI is taken in, stored, organised and maintained, with shared definitions, and DAT-08 records provenance and the preparation and labelling steps applied to each data set. Ownership (DAT-02) and quality requirements (DAT-03) complete the documented data management processes.
A.7.3Record how data is acquired and selectedDAT-08 direct
A.7.4Data quality requirements metDAT-03 direct
A.7.5Record data provenanceDAT-08 direct
A.7.6Criteria and methods for data preparationDAT-08 direct, DAT-03 partialDAT-08 Level 3 records the preparation and labelling steps applied to each data set used to train, tune or test AI, and how synthetic and augmented data were generated and checked; DAT-03 quality requirements for each use give the criteria the prepared data must meet. Choosing particular preparation techniques is system-level.
A.8.2Give users the information they needTEC-05 direct, RSK-08 partial, PPL-08 partial, GOV-09 partialTEC-05 Level 3 requires documentation for each version, suited to users, stating intended purpose and users, how it works, inputs and outputs, known limitations and where it must not be relied on, and PPL-08 tool guidance states limitations, failure modes and residual risks. RSK-08 explains to affected people and GOV-09 publishes records.
A.8.3A way for others to report adverse impactsMON-06 partial, RSK-08 partialFeedback (MON-06) and challenge (RSK-08) give routes in; a route specifically for reporting adverse impacts is not explicit.
A.8.4A plan for telling users about incidentsMON-09 directMON-09 Level 3 includes a plan for telling affected people about serious incidents, alongside notification routes for suppliers and regulators. Telling users about lesser incidents is not explicit.
A.8.5Know and meet reporting obligations to interested partiesRSK-04 direct, GOV-09 partial
A.9.2Ways of working that keep use of AI responsibleGOV-01 partial, PPL-08 partial, RSK-05 partialPolicy, principles and staff support shape responsible use; documented processes for responsible use are spread across controls rather than explicit.
A.9.3Goals that steer how AI is used responsiblyRSK-05 partial, STR-02 partialPrinciples (RSK-05) and strategic boundaries (STR-02), which name the kinds of decision that must always be taken by a person, set direction; documented objectives for responsible use are not explicit.
A.9.4Use AI only as intendedMON-02 direct, TEC-06 partial, GOV-03 partialMON-02 Level 3 monitors each use against its defined operating conditions, as well as AI from others against the provider's instructions for use; TEC-06 defines those conditions and enforces them by limits, and GOV-03 approval sets the purpose.
A.10.2Allocate responsibilities with partners, suppliers and customersOPM-04 direct, GOV-05 partial
A.10.3Suppliers align with the responsible approachRSK-09 direct, OPM-05 partial
A.10.4Consider customer expectations and needsCUL-08 partial, MON-06 partialPublic and customer trust (CUL-08) and feedback (MON-06) consider expectations; building customer needs into the responsible approach is not explicit.

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