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ISO/IEC 42001 Clauses 4 to 10: What a Lead Implementer Produces at Each

Last Updated : October 7, 2026
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ISO/IEC 42001 clauses 4 to 10 are the auditable requirements of the AI management system standard, written in the harmonized structure that ISO management system standards share. Clause 4 covers context, 5 leadership, 6 planning, 7 support, 8 operation, 9 performance evaluation and 10 improvement. Clauses 1 to 3 set scope, references and vocabulary. A certification audit tests clauses 4 to 10 together with the Annex A controls the organization selects.

Each subclause is read from the implementer’s chair. You get the decision or record it produces, a suggested owner, what an auditor checks, and a common mistake. Requirements are paraphrased and never quoted at length. Check exact wording against your licensed copy of ISO/IEC 42001:2023.

How the ten clauses are organized

ISO/IEC 42001 is built from ten numbered clauses and then Annexes A to D. The first three clauses set the frame. Clauses 4 to 10 contain the “shall” statements an auditor tests. At the lowest level of numbering, clauses 4 to 10 break into 32 subclauses, from 4.1 to 10.2.

Four annexes sit behind the clauses. Annex A lists reference control objectives and controls, and Annex B gives implementation guidance for them; both are normative. Annexes C and D are informative. Per Annex A of ISO/IEC 42001:2023, there are 38 controls in nine areas (A.2 to A.10) under ten control objectives. Check each control’s wording in your licensed copy.

The clause text has not moved since publication. As of 30 September 2026, ISO’s catalogue entry for ISO/IEC 42001:2023 shows it as the current edition, with no amendment or revision in progress. CEN adopted the standard without modification as EN ISO/IEC 42001:2026 on 13 March 2026, so European copies carry a different label over the same clauses.

Clauses 1 to 3: scope, one reference and the vocabulary

Clauses 1 to 3 of ISO/IEC 42001 define who the standard is for, which other document it depends on, and what its words mean. An auditor spends little time here, yet each one shapes how the later clauses read. One note does carry “shall” wording: Note 2 to 3.26 requires every identified risk and its controls to be reflected in the SoA.

  • Clause 1 (scope) applies the standard to any organization that provides or uses products or services built on AI systems, whatever its size, type or nature. It sets requirements and guidance for an AIMS.
  • Clause 2 names one normative reference, ISO/IEC 22989:2022, the AI concepts and terminology standard. The reference is dated, so the 2022 edition is the one that applies.
  • Clause 3 imports the terms of ISO/IEC 22989 and adds 26 entries numbered 3.1 to 3.26. Three of them feed directly into later work: AI system impact assessment (3.24), data quality (3.25) and statement of applicability (3.26).

Two definitions change how you scope the work. Under 3.1, “organization” means only the part of a larger entity that sits inside the AIMS scope. Under 3.3, top management can be those who direct that unit. A business unit can therefore run its own AIMS with its own leadership sign-off.

The harmonized structure behind clauses 4 to 10

The harmonized structure is the common clause skeleton that ISO management system standards use, also known by its older name, Annex SL. ISO/IEC 42001 states that it applies that structure, with identical clause numbers, clause titles, core text and common definitions. Its Annex D adds that ISO/IEC 27001 uses the same high-level structure, which makes running the two together easier.

For an implementer, the shared skeleton has two consequences. Management system machinery like document control, audit programs and review meetings can be shared with an existing ISMS or QMS. The AI-specific text, though, sits inside the shared clauses, mostly in 4.1, 6.1 and 8.2 to 8.4.

PDCA as a reading aid

The PDCA cycle (Plan, Do, Check, Act) is the improvement loop ISO uses to describe ISO/IEC 42001. ISO’s AI management systems page says the standard “is built around a ‘Plan-Do-Check-Act’ process”. The mapping below is GAICC’s reading; the standard prints no such table.

PDCA phaseClausesWhat the phase delivers
Plan4, 5, 6Scope, roles, policy, risk criteria, assessments, the SoA and objectives
Do7, 8Resources, competent people, controlled documents and assessments run in operation
Check9Metrics, internal audits and management review decisions
Act10Corrective actions and improvements fed back into planning

Some guides put clause 7 under Plan. Either view works. Audit findings cite clause numbers.

Clause order and build order

ISO/IEC 42001 states that the order of its requirements does not show their importance or the order in which to implement them. In practice, scope and the list of AI systems in use come early, because 4.1 roles drive which controls apply. The impact assessment method usually exists before the Statement of Applicability is final, since its results feed the risk assessment.

With the frame set, the next question is what each subclause asks of you.

Every subclause from 4.1 to 10.2 in one table

The master table lists all 32 subclauses of ISO/IEC 42001 clauses 4 to 10 with the implementer output for each. Owner suggestions are GAICC editorial: the standard names top management and “designated management” in a few places and leaves every other assignment to you.

SubclauseWhat it asks for, in briefWhat the implementer producesSuggested ownerWhat the auditor checks
4.1 ContextRelevant issues, a climate change decision, the purpose of each AI system and the organization’s role toward itContext register with issues, climate decision and an AI role per systemAIMS lead with AI system ownersRoles match how each system is built, sold or used
4.2 Interested partiesRelevant parties, their requirements, and which ones the AIMS addressesInterested party register with a decision columnAIMS lead with legalLegal and contract duties appear with an owner
4.3 ScopeBoundaries and applicability, informed by 4.1 and 4.2, kept as documented informationApproved scope statement naming units, AI systems and rolesTop management approvesStage 1 reads it; Stage 2 tests it against live systems
4.4 AIMSSet up, run, maintain, improve and document the system and its processesProcess map showing how AIMS processes connectAIMS leadProcesses run in practice as drawn
5.1 LeadershipVisible commitment: policy fit with strategy, resources, integration, directionMinutes, budget decisions and messages from leadershipTop managementInterviews with top management
5.2 AI policyA policy fit for purpose, a frame for objectives, commitments to requirements and improvementApproved AI policy with version and dateTop managementApproval evidence; staff can find it
5.3 RolesAssigned, communicated duties, including AIMS conformity and performance reportingRole descriptions or a RACI, plus appointment recordsTop managementNamed holders for the two duties the clause lists
6.1.1 GeneralRisks and opportunities, and AI risk criteria that separate acceptable from unacceptable riskAI risk criteria and an action planRisk lead; criteria approved by managementCriteria cover harm to people as well as to the business
6.1.2 AI risk assessmentA repeatable way to identify, analyze and evaluate AI risksRisk method and risk registerRisk lead with system ownersScores stay consistent across systems
6.1.3 AI risk treatmentTreatment options, necessary controls checked against Annex A, an SoA with reasons, a plan, sign-offStatement of Applicability, treatment plan, residual risk acceptanceRisk lead prepares; designated management approvesA reason for each exclusion; signed acceptance
6.1.4 AI system impact assessmentA process to assess consequences for individuals, groups and societies, with results fed into 6.1.2Impact assessment procedure and templateAI system owner with an impact assessorResults visibly changed a risk entry
6.2 AI objectivesMeasurable objectives tied to the policy, monitored and documented, with a plan to reach themObjectives register with measure, owner and dateTop management sets; owners deliverProgress data per objective
6.3 Planning of changesChanges to the AIMS made in a planned wayAIMS change logAIMS leadOne recent change and its plan
7.1 ResourcesResources for the AIMS determined and providedResource plan or budget lineTop managementNamed roles have time and tools
7.2 CompetenceRequired competence defined and met, gaps closed, evidence keptCompetence matrix and evidence filesLearning lead with AIMS leadEvidence for people in sampled roles
7.3 AwarenessPeople know the AI policy, their part and the cost of not conformingAwareness material and completion recordsAIMS leadShort staff interviews
7.4 CommunicationWhat, when, with whom and how the AIMS communicatesCommunication planAIMS leadOne planned message and proof it went out
7.5.1 GeneralDocuments the standard requires plus those you decide you needRegister of documents and recordsDocument controllerListed items exist
7.5.2 Creating and updatingIdentification, format, review and approvalTemplate with owner, version and approval fieldsDocument controllerApproval fields on sampled documents
7.5.3 ControlAvailability, protection, distribution, retention and version controlDocument control procedureDocument controllerVersion history and access rules
8.1 Operational planning and controlControlled processes that carry out the clause 6 actions, including outsourced onesOperating procedures, criteria and supplier controlsProcess ownersOne AI system traced through its controls
8.2 AI risk assessmentRisk assessments run on a planned cycle and after significant change; results keptDated assessment recordsRisk leadDates against the plan and the change log
8.3 AI risk treatmentThe treatment plan carried out and checked; results keptTreatment status recordsControl ownersProof a treatment happened and worked
8.4 AI system impact assessmentImpact assessments run on a planned cycle and when significant changes are proposed; results keptCompleted impact assessment recordsAI system ownerA changed system with a fresh assessment
9.1 Monitoring and measurementWhat to measure, how, when to measure and when to analyze; results evidencedMetric set and resultsAIMS lead with ownersTrend data and who reviewed it
9.2.1 Internal audit, generalAudits at planned intervals on conformity and effective implementationAudit reportsInternal audit leadAudits scheduled and carried out
9.2.2 Internal audit programFrequency, methods, duties, planning and reporting; objective auditorsAudit program and audit plansInternal audit leadAuditors did not audit their own work
9.3.1 Management review, generalTop management reviews the AIMS at planned intervalsReview calendarTop managementReviews took place
9.3.2 Review inputsPast actions, changes in issues and needs, performance trends, improvement optionsReview packAIMS leadEvery input is present
9.3.3 Review resultsDecisions on improvement and needed changes, evidencedMinutes with decisions and actionsTop managementDecisions traced into actions
10.1 Continual improvementOngoing improvement of suitability, adequacy and effectivenessImprovement logAIMS leadImprovements beyond fixes
10.2 Nonconformity and corrective actionReact, find causes, look for similar cases, act, check effectiveness, update the AIMSCorrective action recordsProcess owner; AIMS lead tracksRoot cause and an effectiveness check

Several subclauses name no documented information at all, among them 4.1, 5.3 and 7.3. Auditors still ask for evidence there, so plan a record even where the text does not demand one. Working through these 32 rows with an instructor is the core of GAICC’s Lead Implementer course that works through clauses 4 to 10. Every clause in that range gets at least one module, and the course ends with certification preparation.

Clause 4: context of the organization

Clause 4 of ISO/IEC 42001 decides what the AIMS covers and from whose point of view, and its four subclauses produce the context register, the interested party register, the scope statement and the process map.

The AI-specific demand sits in 4.1. The organization considers the intended purpose of each AI system it develops, provides or uses, and determines its role toward each one. A note lists six role families taken from ISO/IEC 22989: AI providers, AI producers, AI customers, AI partners, AI subjects and relevant authorities. The standard adds that roles can decide whether, and how far, its requirements and controls apply. A wrong role in clause 4 therefore becomes a wrong exclusion in the SoA.

Watch one naming trap, because in 42001 “AI deployer” sits inside the AI producer family, while the legal term “deployer” in the EU AI Act and in Colorado law means something else. Keep legal labels out of the role column.

Clause 4.1 also asks whether climate change is a relevant issue, and the decision should be recorded either way, with a reason. For AI, compute and energy use are the usual starting point.

At Stage 1 the auditor reads the scope statement and compares it with what the organization sells and uses. At Stage 2 the auditor picks an AI system and asks for its role and issue entries. Teams often write scope as a list of departments and never name the AI systems inside it. The text of ISO/IEC 42001 does not contain the term “inventory”, yet a list of AI systems is the practical input to 4.1 and 4.3. The guide to getting the scope right covers role choice and scope wording in depth.

Clause 5: leadership

Top management carries three duties under clause 5 of ISO/IEC 42001: show commitment (5.1), set the AI policy (5.2) and assign roles (5.3). The Lead Implementer prepares the material, but the signatures belong to leadership.

Under 5.2, top management sets a policy that suits the organization’s purpose, frames the AI objectives and commits to meeting requirements and to continual improvement. The policy must be documented, linked to other policies, communicated inside the organization and available to interested parties where appropriate. Writing it well is covered in the AI policy guide.

Clause 5.3 asks top management to assign and communicate responsibilities and authorities. Two duties must have a named owner: keeping the AIMS in conformity with the standard, and reporting AIMS performance to top management. Everything else is your design, which is why a RACI helps. See the roles clause 5 expects for a worked RACI.

Expect interviews with leadership, approval records for the policy and named people for the two duties in 5.3. Two errors recur. In the first, a committee or a security lead approves the AI policy and no one at top management level signs. In the second, a RACI lists every activity but leaves performance reporting unassigned.

Clause 6: planning

Clause 6 of ISO/IEC 42001 is where the AIMS decides what could go wrong, what it will do about it and what it is aiming for. Six subclauses produce the risk criteria, the risk method, the Statement of Applicability, the treatment plan, the impact assessment process, the objectives and the change plan. The full treatment of what clause 6 asks for sits on GAICC’s risk page.

6.1.1 and 6.1.2: risk criteria and risk assessment

AI risk criteria in 6.1.1 separate acceptable from unacceptable risk and support risk assessment, treatment and the assessment of AI risk impacts. Risks are determined in light of each system’s domain, application context and intended use. Clause 6.1.2 then asks for an assessment process that gives consistent, comparable results. Its analysis step looks at consequences for the organization, for individuals and for societies.

The output is a written method plus a risk register, and a frequent error is to reuse an information security matrix scored only on confidentiality, integrity and availability. A matrix like that has no place to record harm to a person who is denied a loan.

6.1.3: risk treatment, the SoA and sign-off

Clause 6.1.3 turns assessed risks into chosen controls, so the organization picks treatment options and determines the controls each one needs. It checks them against Annex A so no needed control is overlooked, adds its own controls where Annex A falls short and considers the Annex B guidance. It then produces a Statement of Applicability and an AI risk treatment plan.

Two approvals sit here. Designated management approves the treatment plan and accepts the residual AI risks. In most organizations that approver sits above the Lead Implementer, who prepares the pack.

A Statement of Applicability lists the necessary controls and justifies each inclusion and exclusion. Two grounds justify an exclusion: the risk assessment found the control unnecessary, or external requirements do not call for it. Annex A is neither mandatory nor exhaustive, as a note to the 3.26 definition says. Read justifying each control you include or exclude before you draft the SoA, and browse the Annex A control set for the controls themselves.

6.1.4: the AI system impact assessment

Clause 6.1.4 asks for a defined process that assesses the consequences an AI system can have for individuals, groups and societies. It covers deployment, intended use and foreseeable misuse, and it takes account of the technical and social setting and the jurisdictions involved. Results are documented and must be considered in the 6.1.2 risk assessment.

The popular line “risk looks inward, impact looks outward” does not fit 42001, because 6.1.2 already weighs harm to individuals and societies. The impact assessment stands as its own documented process, and its findings flow into the risk assessment. Method, triggers and evidence are covered in the AI system impact assessment guide.

[TRAINER INSIGHT NEEDED: In GAICC Lead Implementer course exercises, which clause 6 output do candidates most often get wrong, and what does the corrected version look like?]

6.2 and 6.3: objectives and planned change

AI objectives under 6.2 must align with the AI policy and be measurable where practicable. They are monitored, communicated, updated and documented. For each one, the plan names what will be done, the resources, the owner, the deadline and how results will be judged. Clause 6.3 asks that changes to the AIMS itself be made in a planned way.

Stage 1 looks for the method, the SoA and the plan. Stage 2 traces one risk from register entry to control to evidence, and checks the residual risk signature.

Clause 7: support

People, knowledge and documents are what clause 7 of ISO/IEC 42001 secures for the AIMS. The outputs are a resource plan, a competence matrix, awareness records, a communication plan and a document control system.

Resources come first. Under 7.1 the organization determines and provides what the AIMS needs. Annex A expands this for AI through its area on resources for AI systems, which covers data, tooling, computing and human resources.

Competence under 7.2 starts with defining what each AI-affecting role needs. The organization then shows people meet it, closes gaps and checks the actions worked, keeping the evidence. Attendance lists alone do not prove competence, because they skip the first step. GAICC’s page on competence evidence sets out what counts.

Awareness and communication (7.3 and 7.4) are short subclauses. People doing work under the organization’s control should know the AI policy, how they contribute and what happens if they do not conform. The communication plan answers what, when, with whom and how.

Documented information under 7.5 covers documents the standard requires plus those you decide you need. Each is created with an owner and approval, then controlled for access, version and retention. GAICC’s page on clause 7.5 requirements lists each required document.

Teams often treat awareness as a training course. An auditor tests awareness by asking a developer where the AI policy lives and what it means for their work.

Clause 8: operation

Clause 8 of ISO/IEC 42001 puts into operation what clause 6 designed. Each planning step has an operating twin: 6.1.2 pairs with 8.2, 6.1.3 with 8.3 and 6.1.4 with 8.4.

Subclause 8.1 asks the organization to plan and control the processes needed to meet requirements and carry out the clause 6 actions. Process criteria are set and applied. Externally provided processes, products or services that matter to the AIMS must be controlled too. For most organizations, that phrase is where a hosted model from a supplier enters the AIMS.

Subclauses 8.2 to 8.4 set repeat cycles. Risk assessments are rerun at planned intervals and when significant changes are proposed or occur. Impact assessments are rerun at planned intervals and when significant changes are proposed. The treatment plan is carried out and its effect checked. Results of all three are retained as records.

At Stage 2, auditors take one AI system and walk it through its life: requirements, data, testing, release, monitoring, and they compare assessment dates with the change log. A typical gap is an impact assessment written once for certification and never reopened. Define “significant change” in advance, for example a new user group, a new data source or a retrained model. Without a definition, nobody knows when 8.2 or 8.4 should trigger.

Clause 9: performance evaluation

Whether the AIMS works is the question behind clause 9 of ISO/IEC 42001, performance evaluation. Its outputs are a metric set, an internal audit program with reports, and management review minutes.

9.1 Monitoring, measurement, analysis and evaluation

Under 9.1 the organization decides what to measure, how, when to measure and when to analyze the results. Results are kept as evidence, and the organization evaluates both AIMS performance and effectiveness. Objectives from 6.2 are the natural first metrics.

[TRAINER INSIGHT NEEDED: Which AIMS performance measures do GAICC instructors suggest for an organization’s first year under clause 9.1, and why those?]

9.2 Internal audit

Internal audits under 9.2 run at planned intervals and check conformity with the organization’s own AIMS rules and with the standard, and whether the AIMS is effectively implemented and maintained. The program sets frequency, methods, responsibilities and reporting, and auditors are chosen for objectivity and impartiality. Clause 3.18 allows an external party to run the audit on the organization’s behalf. Set up the internal audit program before you book a certification body.

9.3 Management review

Management review under 9.3 happens at planned intervals. Inputs include actions from earlier reviews, changes in issues and stakeholder needs, performance trends and improvement options. Outputs are decisions on improvement and on changes to the AIMS, kept as evidence.

A sentence that circulates widely says “ISO 42001 requires an annual internal audit and an annual management review.” The standard’s wording is planned intervals. The yearly rhythm comes from certification rules. ISO/IEC 17021-1 calls for surveillance audits at least once a calendar year outside recertification years, according to an accreditation body’s summary of its section 9. The same summary lists a Stage 1 objective: confirm the internal audit and management review are planned and under way. So both must exist before Stage 1, whatever cycle you choose.

Clause 10: improvement

Improvement under clause 10 of ISO/IEC 42001 closes the loop. Subclause 10.1 asks for continual improvement of the AIMS’s suitability, adequacy and effectiveness. Subclause 10.2 sets the steps for a nonconformity.

When something fails, the organization reacts and corrects it, deals with the consequences, finds the cause and checks whether similar failures exist or could occur. It then acts, reviews whether the action worked and changes the AIMS if needed. Records show what went wrong, what was done and the result.

The “similar cases” step matters more for AI than for most systems. A data labeling flaw found in one model often sits in other models trained from the same pipeline. Check the siblings before you close the record.

Auditors sample closed items and ask how you confirmed the fix worked. A finding closed with a correction alone, with no root cause or effectiveness check, leaves nothing to show them. Teams that want structured practice on that loop can take clause-by-clause implementation training, whose modules on nonconformities and corrective action lead into a mock audit.

Clauses 4 to 10 now have their outputs. The remaining questions are how they differ from ISO 27001 and where readers most often go wrong.

Where 42001 departs from ISO 27001

ISO/IEC 42001 and ISO/IEC 27001 share clause numbers and titles, so the differences sit inside the text and in the annexes. The table lists the ones that change an implementer’s workload.

PointISO/IEC 27001:2022ISO/IEC 42001:2023What it means for you
Risk criteria (42001 6.1.1; 27001 6.1.2)Criteria for information security riskAI risk criteria that also support assessing AI risk impactsNew criteria for harm to people
Risk analysis (6.1.2)Risks tied to loss of confidentiality, integrity and availabilityConsequences for the organization, individuals and societiesRescore inherited risks
Impact assessment (6.1.4, 8.4)No equivalentSeparate documented process, rerun on schedule and on changeA new process and new records
SoA content (6.1.3)Necessary controls, reasons, and whether each is implementedNecessary controls with reasons for inclusion and exclusionImplementation status becomes optional good practice
Annex guidanceAnnex A normative; guidance in a separate standard, ISO/IEC 27002Annex A normative, and Annex B implementation guidance is also normativeRead Annex B as part of the standard
Organizational role (4.1)Not addressedRole toward each AI system determines applicabilityA role column for every system

Climate change is no longer a difference. ISO/IEC 27001 gained a climate change amendment in 2024, and 42001 included the climate question from the start. For integration steps, read the full ISO 42001 and ISO 27001 comparison.

Common misreadings of clauses 4 to 10

Several statements about ISO/IEC 42001 clauses circulate on ranking pages and in forum threads, and the standard does not support them. Each row gives the claim and what the text supports instead.

ClaimWhat the standard supports
Internal audits and management reviews must happen every yearPlanned intervals; the yearly cycle comes from certification body rules
Risk assessment looks inward, impact assessment looks outward6.1.2 already covers individuals and societies; 6.1.4 is a separate process feeding it
Annex B is informativeAnnex B is normative; Annexes C and D are informative
Clause 6.1.4 covers objectives for risk treatment6.1.4 is the AI system impact assessment; objectives sit in 6.2
You implement the clauses in order, 4 to 10The standard says its order is not an implementation order
ISO 42001 requires an “AI inventory”The word is absent; the need is traced through 4.1, 4.3 and the Annex A resource controls
Every Annex A control must be implementedAnnex A is neither mandatory nor exhaustive; exclusions need reasons

Where to begin, by starting position

Your organization’s role and the systems it already runs decide which clauses to open first.

Starting positionClauses to open firstWhy
You build or sell AI systems4.1 roles, then 6.1.4 and 8.4Producer and provider roles are where the A.6 life cycle controls apply most clearly
You only use third-party AI4.1, 8.1 and the A.10 supplier controlsYour role is mostly AI customer; the impact assessment still covers how you use each system
You hold ISO/IEC 27001 certification6.1 criteria, 6.1.4, 8.4 and a new SoAClauses 5, 7, 9 and 10 machinery can be reused
You are a consultant running a gap reviewAll 32 rows of the master tableMark “evidence exists” or “evidence missing” per row
You are preparing for the Lead Implementer examClauses 4 to 10 in order, then 6.1.2 to 6.1.4 and 8See how the GAICC exam weights these clauses by domain

For the standard as a whole, including certification and the wider family, start with the standard itself.

Frequently asked questions

What are the requirements of ISO 42001?

The requirements are the “shall” statements in clauses 4 to 10, which split into 32 subclauses from context in 4.1 to corrective action in 10.2. Clause 6.1.3 adds a comparison with the 38 Annex A controls, with each inclusion and exclusion recorded in a Statement of Applicability. Annex B guidance is normative too, while Annexes C and D are informative.

What is the focus of clause 9 in ISO 42001?

Clause 9 asks whether the AIMS is working. Subclause 9.1 sets what you measure and when, 9.2 runs internal audits at planned intervals, and 9.3 has top management review the system and record decisions. The evidence from all three feeds the corrective actions and improvements in clause 10.

Are all of clauses 4 to 10 required for certification?

ISO/IEC 42001 gives an exclusion route only for controls, through the justification rules in 6.1.3 and its notes. Clauses 4 to 10 have no equivalent route, so plan to evidence every subclause, including the ones that name no documented information. Whether the standard itself is mandatory for your organization is a separate question, answered in GAICC’s overview of the standard.

How detailed should a clause-by-clause gap check be?

Work at subclause level, one row for each of the 32 subclauses, because auditors sample at that depth. For each row, record the output that should exist, where the evidence sits and whether it is current. Add a row for each Annex A control you plan to include, since the Statement of Applicability is tested alongside the clauses.

Does an ISO 27001 certificate help with the ISO 42001 clauses?

It helps with the shared machinery. Annex D of ISO/IEC 42001 notes that both standards use the same high-level structure, so document control, internal audit and management review can usually be extended. The AI work is new: risk criteria in 6.1.1, an impact assessment under 6.1.4 and 8.4, and a Statement of Applicability against the 42001 annex.

What happens to clauses 9 and 10 after certification?

Clauses 9 and 10 keep running for the life of the certificate. An accreditation body’s summary of ISO/IEC 17021-1 describes a three-year cycle, with surveillance audits in years one and two and recertification in year three. Each surveillance audit reviews internal audits, management review and action on earlier nonconformities, and Stage 1 and Stage 2 certification audits covers the audit stages..

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About the Author

Dr Faiz Rasool

Director at the Global AI Certification Council (GAICC) and PM Training School

A globally certified instructor in ISO/IEC, PMI®, TOGAF®, SAFe®, and Scrum.org disciplines. With over three years’ hands-on experience in ISO/IEC 42001 AI governance, he delivers training and consulting across New Zealand, Australia, Malaysia, the Philippines, and the UAE, combining high-end credentials with practical, real-world expertise and global reach.

About the Author

Latha Karthigaa

Head of AI Governance at the Global AI Certification Council (GAICC)

A PhD-qualified AI governance leader in Software Engineering from the University of Auckland, she brings hands-on experience founding and exiting AI companies, and leading real-world AI solutions for finance and legal firms across the USA, UK, Australia, and New Zealand, combining governance, risk, compliance, and commercial expertise.

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