Scope and your role
Which AI systems are covered, and whether you act as developer, provider, user, or all three.
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Austin, Texas · 14 weeksSOC 2 Type II Readiness for an HR PlatformAn AI management system that conforms to ISO/IEC 42001, holds up against the NIST AI RMF and the EU AI Act, and is tested as an adversary would.
Vendor models in underwriting, language models in service, assistants in engineering, and pilots nobody approved.
Few have an owner, a documented purpose or someone with authority to stop them. ISO/IEC 42001 gives every new use case a process that already knows how to evaluate it.
The management-system core, shared with ISO/IEC 27001
AI control objectives, A.2 to A.10
AI risk and AI system impact, distinct obligations
A policy that says “use AI responsibly” is not a control. A control is a named person who can stop a model.
Every system, whether built, bought or embedded, with an owner, a purpose and a risk tier.
Risk and impact assessments that show why each use was approved.
Human review designed into the workflow, with real authority to intervene.
An evidence pack prepared for an accredited body’s Stage 1 and Stage 2 audits.
Clauses 4–10 define the management system; Annex A sets reference controls for AI. These are its distinctive demands.
Which AI systems are covered, and whether you act as developer, provider, user, or all three.
A repeatable method for risks to the organization, individuals and society.
Documented consequences for the people a system affects, revisited on change.
Design, verification, deployment and monitoring controls that were actually applied.
Provenance and quality of training and evaluation data, the most common weak point.
Responsibilities allocated with the suppliers of the models you depend on.
Summarized from ISO/IEC 42001:2023; the published standard governs.
Change a system’s risk answers and watch its tier and controls update. Open the red-team findings to see a hidden instruction reach a refund tool.
Fictional organization, synthetic data. Real engagements test real models under agreed rules of engagement.
Built, bought, embedded and shadow use.
Assessments with use-case owners; gap against clauses 4–10.
Policy, roles, life-cycle and supplier controls.
Red teaming, internal audit and readiness check.
New use cases, model changes and regulation.
Owner, purpose, data, supplier and risk tier for every system.
Annex A controls selected and justified from risk treatment.
Findings mapped to OWASP LLM Top 10 and MITRE ATLAS.
An independent view of readiness for certification.
42001 is the structure. The NIST AI RMF and EU AI Act shape what goes inside it.
| Control area | ISO/IEC 42001 | NIST AI RMF | EU AI Act | ISO/IEC 27001 |
|---|---|---|---|---|
| AI policy and accountability | Directly addressed | Directly addressed | Partially addressed | Partially addressed |
| Risk assessment and treatment | Directly addressed | Directly addressed | Directly addressed | Partially addressed |
| Impact assessment on people | Directly addressed | Directly addressed | Partially addressed | Not addressed– |
| Data governance and quality | Directly addressed | Directly addressed | Directly addressed | Partially addressed |
| Human oversight | Directly addressed | Directly addressed | Directly addressed | Not addressed– |
| Robustness and cybersecurity | Partially addressed | Directly addressed | Directly addressed | Directly addressed |
| Third-party management | Directly addressed | Directly addressed | Partially addressed | Directly addressed |
Directly addressed Partially addressed or different evidence expectations , Not a primary objective. EU AI Act obligations depend on system classification and your role. The Digital Omnibus on AI moved most stand-alone high-risk obligations to December 2027.
Extend model risk management to language models, and classify credit and insurance-pricing uses carefully under the EU AI Act.
Over-reliance on generated summaries is a patient-safety risk. Impact assessments need a clinical-safety frame.
42001 increasingly answers enterprise procurement. The challenge: release gates that keep pace with weekly model changes.
Transparency, contestability and fundamental-rights impact assessment carry particular weight.
Hidden instructions in documents hijack a model that cannot tell data from commands.
Retrieval that ignores entitlements; secrets in prompts.
Agents with broad tools and no approval gate.
Performance shifts with no threshold, owner or trigger.
A supplier updates a hosted model overnight.
Poisoned embeddings and weak tenant isolation.
Scope and the AI roles you play.
OutputScope statement
Discovery and clause-by-clause gap.
OutputInventory and gap report
Methods, SoA and controls.
OutputManagement-system documentation
Red teaming of priority systems.
OutputRed-team report
Internal audit and management review.
OutputReadiness report
An accredited certification body. We build, test and internally audit your management system, help you choose the body and support you through Stage 1 and Stage 2.
Most of the management-system machinery: document control, internal audit, management review and corrective action. The AI-specific risk, impact, life-cycle and oversight content is new.
Not by itself. It is an excellent vehicle for many AI Act obligations, but those depend on how a system is classified and your role. We map the gaps explicitly.
Yes. For buyers the emphasis shifts to inventory, intended use, supplier assessment and monitoring.
Rules of engagement and stop conditions are agreed in advance. Most testing runs in staging; any production testing is tightly scoped and approved.
A confidential conversation about your AI portfolio, your obligations and where the inventory should begin.