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ISO/IEC 42001 Annex A Controls: Objectives, Controls and the Evidence Each Needs

Last Updated : October 7, 2026

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ISO/IEC 42001 Annex A is the normative annex that sets out reference control objectives and controls, which an organization checks its AI risk treatment against. Per Annex A of ISO/IEC 42001:2023, there are 38 controls, grouped under ten control objectives across nine areas numbered A.2 to A.10. No control is automatically mandatory. Under clause 6.1.3 you compare the controls your risk treatment needs with Annex A. You then record each inclusion and each exclusion, with a reason, in the Statement of Applicability.

The Annex A in ISO/IEC 42001 should not be confused with the one in ISO/IEC 27001. The 27001 annex holds 93 information security controls. The 42001 annex governs AI work: impact assessment, data provenance, intended use and supplier responsibilities. Annex A also differs from Annex B. Annex B gives implementation guidance for the same controls and numbers its sections B.2 to B.10 to match. The register on this page lists all 38 controls, each with its plain-English intent, the usual evidence and the usual owner.

GAICC paraphrases the standard here and reproduces only control numbers and short titles. Before building a register from it, confirm each control’s wording in your licensed copy of ISO/IEC 42001:2023.

Annex A status and counts at a glance

ISO/IEC 42001 labels Annex A normative in its published table of contents, and it labels Annex B normative as well. C and D carry the informative label. A normative annex is part of the requirements text, so an auditor may test whether you know it and how you applied it.

AnnexPublished labelTitle (short)What it gives an implementer
ANormativeReference control objectives and controlsThe 38 controls you compare your risk treatment against
BNormativeImplementation guidance for AI controlsOne guidance section for each Annex A control
CInformativePotential AI-related organizational objectives and risk sourcesCandidate AI objectives and risk sources for clauses 6.1 and 6.2
DInformativeUse of the AI management system across domains or sectorsSector notes and integration with other management systems

Page numbers in the published table of contents show where the weight sits. Annex A starts on page 17 and takes about four pages, while Annex B starts on page 21 and runs until Annex C begins on page 46. Most of what you need to know about a control sits in its Annex B section, since the Annex A entry is a single sentence.

Per-area counts

ISO/IEC 42001 Annex A opens with A.1, a general clause, and places its controls in nine areas from A.2 to A.10. Each area starts with an objective, and A.6 carries two of them: one for management guidance on AI system development (A.6.1) and one for the life cycle itself (A.6.2). That gives ten objectives in all.

AreaArea titleObjectivesControls
A.2Policies related to AI13
A.3Internal organization12
A.4Resources for AI systems15
A.5Assessing impacts of AI systems14
A.6AI system life cycle29
A.7Data for AI systems15
A.8Information for interested parties of AI systems14
A.9Use of AI systems13
A.10Third-party and customer relationships13
Total 1038

The counts are per Annex A of ISO/IEC 42001:2023. Confirm each control’s wording in a licensed copy.

What ranking pages and AI answers get wrong

Several pages that rank for Annex A searches carry structural errors. GAICC checked them against the published table of contents and found six patterns, listed here without naming the publishers.

What the page or answer saysWhat the published text shows
A guide on page one of Google calls A.5 “AI System Lifecycle” and A.6 “Data”, and lists eight areasNine areas; A.5 holds the four impact assessment controls the guide drops
Annex B is informative (at least two ranking pages)ISO’s published contents list marks Annex B normative
Annex A is informative (a documentation site AI answers cite on the SoA)Annex A is normative
Annex A has nine control objectivesNine areas and ten objectives, because A.6 has two
A widely cited vendor guide summarizes A.2 as two controls, A.5 as three and A.6 as elevenIts own detailed headings list three, four and nine
A Google AI answer lists A.2.3 as a review control and A.2.4 as an availability controlA.2.3 is alignment with other policies and A.2.4 is review of the AI policy

Normative status still leaves room for selection. A note in the standard’s own definition of the Statement of Applicability says an organization might need fewer controls than Annex A lists, or more. What the normative label adds is that the selection itself can be audited.

All 38 Annex A controls in one register

The register lists every ISO/IEC 42001 Annex A control by ID and short title, as publicly enumerated. The “What it asks” column is GAICC’s plain-English paraphrase of each control’s intent. The evidence and owner columns are GAICC editorial guidance, because the standard names no job titles. Treat each title and paraphrase as provisional until you have matched it to a licensed copy.

IDShort titleWhat it asks (GAICC paraphrase)Typical evidenceTypical owner role
A.2.2AI policySet a written policy for how the organization builds or uses AIApproved policy with version and sign-offTop management, drafted by the AIMS lead
A.2.3Alignment with other organizational policiesFind where existing policies touch AI work and align themCross-reference log for privacy, security, procurement and HR policiesAIMS lead with policy owners
A.2.4Review of the AI policyReview the AI policy on a planned cycle and when things changeReview minutes and change historyAIMS lead; top management approves
A.3.2AI roles and responsibilitiesDefine who is responsible for which AI work, then assign itRole descriptions, RACI, appointment recordsTop management
A.3.3Reporting of concernsGive people a protected way to raise concerns about AI systemsReporting procedure and case logEthics or compliance lead
A.4.2Resource documentationIdentify and record what each AI system needs across its life cycleAI system register with resource fieldsAI system owner
A.4.3Data resourcesRecord facts about the data each AI system usesDataset records: source, purpose, category, retentionData owner
A.4.4Tooling resourcesRecord the tools used to build and run AI systemsTool list with versions and platformsML engineering lead
A.4.5System and computing resourcesRecord the computing and infrastructure each system depends onInfrastructure records and cloud account mapPlatform or IT lead
A.4.6Human resourcesRecord the people and skills each system relies onSkills matrix linked to each systemAI system owner with HR
A.5.2AI system impact assessment processRun a defined process for judging consequences for people and societyApproved procedure with triggers and thresholdsAIMS lead or risk lead
A.5.3Documentation of AI system impact assessmentsRecord the results and keep them for a set periodCompleted assessments and a retention ruleImpact assessor
A.5.4Assessing AI system impact on individuals or groups of individualsAssess and record likely effects on people and groupsAffected-group sections with sign-offImpact assessor with legal or privacy
A.5.5Assessing societal impacts of AI systemsAssess and record wider effects on societySocietal impact section with sign-offImpact assessor
A.6.1.2Objectives for responsible development of AI systemSet objectives that steer responsible development and build them into the life cycleDevelopment objectives inside engineering standardsHead of AI or engineering
A.6.1.3Processes for responsible AI system design and developmentDefine and record the design and development processDocumented AI development life cycle with stage gatesEngineering lead
A.6.2.2AI system requirements and specificationSpecify requirements for new systems and major changesRequirements specification with acceptance criteriaProduct owner
A.6.2.3Documentation of AI system design and developmentRecord design and build decisions against the requirementsDesign records, model cards, architecture decisionsML engineering lead
A.6.2.4AI system verification and validationDefine how each system is tested and what counts as a passTest plans, evaluation results, release sign-offsEvaluation or QA lead
A.6.2.5AI system deploymentPlan each release and confirm requirements are met firstRelease plan and go-live approvalRelease manager
A.6.2.6AI system operation and monitoringDefine what running the system involves: monitoring, fixes, updates and supportMonitoring dashboards, runbooks, change ticketsOperations or MLOps lead
A.6.2.7AI system technical documentationDecide what technical documentation each audience needs and supply itDocumentation set per audienceProduct owner
A.6.2.8AI system recording of event logsDecide when event logs are kept, at least while the system is in useLogging settings, retention rules, sample logsPlatform lead
A.7.2Data for development and enhancement of AI systemDefine and run data management for building and improving systemsData management procedureData owner
A.7.3Acquisition of dataRecord how data is obtained and selectedAcquisition records, licenses, legal basisData owner with legal
A.7.4Quality of data for AI systemsSet data quality requirements and check data meets themQuality criteria and validation reportsData steward
A.7.5Data provenanceKeep a record of where data came from and how it changedLineage recordsData engineering lead
A.7.6Data preparationSet criteria for preparing data and record the methods usedPreparation specifications for labeling, cleaning and splittingLead data scientist
A.8.2System documentation and information for usersWork out what users need to know and give it to themUser guides, notices, stated limitationsProduct owner
A.8.3External reportingLet interested parties report adverse impacts of a systemPublic reporting route and intake logCustomer support or compliance
A.8.4Communication of incidentsPlan how AI incidents are communicated to usersIncident communication plan and notices sentIncident manager
A.8.5Information for interested partiesDecide and record what must be reported, and to whomReporting obligations registerLegal or compliance
A.9.2Processes for responsible use of AI systemsDefine how AI systems are used responsiblyAcceptable use procedure and approvalsBusiness system owner
A.9.3Objectives for responsible use of AI systemSet objectives that steer responsible useUse objectives with measuresBusiness system owner
A.9.4Intended use of the AI systemMake sure systems are used as intended and as documentedIntended use statements, usage monitoring, exception recordsBusiness system owner
A.10.2Allocating responsibilitiesSplit life cycle duties between you, partners, suppliers and customersResponsibility matrix in contractsProcurement with legal
A.10.3SuppliersMake sure supplied products and services fit your responsible AI approachSupplier assessments and contract clausesVendor risk or procurement
A.10.4CustomersTake customer expectations and needs into accountCustomer requirements, contract terms, feedback recordsProduct or account lead

Two owner terms recur. The AIMS lead runs the management system day to day. The AI system owner is the business person accountable for one AI system. For a full assignment model, see who does what in an AIMS.

How Annex A controls are selected

ISO/IEC 42001 Annex A controls are selected through AI risk treatment under clause 6.1.3, which starts from your risks and turns to the annex afterward. The sequence below follows the standard’s clause logic as public reproductions of clauses 6.1.2 to 6.1.4 describe it.

  1. Run the AI system impact assessment under clause 6.1.4.
  2. Feed its results into the AI risk assessment under clause 6.1.2.
  3. Pick how to treat each risk and work out the controls each treatment needs.
  4. Check those controls against Annex A to catch anything necessary you left out, and consider the Annex B guidance.
  5. Add any controls the risks need that Annex A does not contain.
  6. Record every control, included or excluded, with a justification in the Statement of Applicability.
  7. Get the treatment plan and the residual AI risks approved by designated management.

Step 4 is where gaps appear. Teams often open Annex A first and write the risk assessment around it. Auditors then find controls with no risk behind them, and risks with no control in front of them.

Exclusions and their grounds

An Annex A exclusion needs a reason an auditor can trace. Secondary reproductions of clause 6.1.3 name two grounds. The risk assessment found the control unnecessary, or no applicable external requirement calls for it. “Not relevant to us” with no link to an assessment result is the weak form, and auditors push back on it.

Your organizational role drives many exclusions. Clause 4.1 requires you to determine your roles with respect to your AI systems. A note to that clause adds that roles can determine which requirements and controls apply, and how far. ISO/IEC 42001 takes its role set from ISO/IEC 22989: AI provider, AI producer, AI customer, AI partner, AI subject and relevant authorities. One trap catches US readers. The “AI deployer” in 22989 is a kind of AI producer. A legal “deployer” under the EU AI Act or Colorado law is a different category.

Illustrative example: an AI customer that builds nothing

The example below is illustrative and built from the standard’s structure. It describes no real organization. Picture a regional bank that licenses a third-party AI writing assistant for its staff and trains no models.

Control groupTypical stance for this bankWhat the bank records
A.6.1.2, A.6.1.3, A.6.2.2 to A.6.2.4Often excludedNo development in scope; the supplier carries design and testing under A.10
A.6.2.5, A.6.2.6, A.6.2.8Usually includedThe bank still rolls out, runs, monitors and logs the assistant
A.7.2 and A.7.6Often excludedNo training or data preparation by the bank
A.7.3 to A.7.5Reopened if staff feed in documentsA connected document store or prompt library is data going into the system
A.5.2 to A.5.5IncludedImpact assessment applies whatever the role
A.9.2 to A.9.4 and A.10.2 to A.10.4Included, and centralUse rules and supplier terms carry most of the risk treatment

The same bank would face a different register if it later fine-tuned a model on customer letters. Role changes reopen the register.

Controls you add yourself

Clause 6.1.3 expects you to add controls that your risks need and Annex A lacks. Agentic AI is the clearest case today. Take an agent that can send email or move money. It may need tool permission limits, human approval for named actions, and a tested way to halt it. None of those has its own Annex A line. Give each one an organization-defined ID, such as ORG.1, and treat it like any other control in the register.

Recording all of this is the job of the Statement of Applicability, which covers columns, versioning and approval in depth.

A.2 Policies related to AI

Policy work under A.2 has three parts: writing the AI policy, aligning it with other policies and reviewing it. A.2.2 echoes clause 5.2. One policy document usually satisfies both. The common finding is a policy that reads like a values statement and commits to nothing an auditor can test. Write each commitment so it points to a process, an owner or a record.

Alignment under A.2.3 is mostly cross-referencing. Privacy, information security, procurement and acceptable use policies all touch AI work, so a short alignment log should show where each one applies and who changed what. Review under A.2.4 runs on a planned cycle and on triggers such as a new regulation or a new class of AI system. The detail of contents, approval and objectives sits in AI policy requirements.

A.3 Internal organization

Accountability is the subject of A.3: who is responsible for AI work and how people raise concerns about it. Clause 5.3 names two assignments top management must make, conformity of the AIMS and reporting on its performance. A.3.2 extends that to every role the AI work needs, from impact assessor to data owner.

A.3.3 asks for a channel to report concerns about AI systems. Annex B points to ISO 37002, the whistleblowing management system standard, for how such a channel can work. Many organizations reuse an existing ethics hotline. That works if the intake form names AI systems and the case log can show AI concerns as a separate category. Keep A.3.3 distinct from A.8.3. Annex B aims A.3.3 at employed and contracted persons, while A.8.3 gives interested parties outside the organization a route to report adverse impacts.

A.4 Resources for AI systems

Resource documentation is the work of A.4, which asks you to record what each AI system depends on: data, tools, computing and people. The word “inventory” does not appear in ISO/IEC 42001. The expectation to know what AI you run is pieced together from clauses 4.1 and 4.3 and the five A.4 controls. In practice A.4 is where the AI system register gets built.

A workable register has one row per AI system, including third-party SaaS tools with AI features. Its columns cover purpose, owner, data sources, tools, hosting and the people who run it. NIST’s AI RMF names the same practice “inventory” in GOVERN 1.6. A.4.6 links to clause 7.2, because the skills you record become the competence you have to evidence. The register also gives auditors their sampling frame, so a missing system weakens every control that depends on it.

A.5 Assessing impacts of AI systems

Four controls in A.5 turn the impact assessment of clause 6.1.4 into a process, documentation, effects on individuals and groups, and effects on society. Under A.5.3 the results are kept for a defined period, so set the retention rule before the first assessment.

The popular split that “risk assessment looks inward, impact assessment looks outward” is wrong under ISO/IEC 42001. Clause 6.1.2 already asks about effects on individuals and on societies. Clause 6.1.4 is a separate documented assessment whose results feed the risk assessment. Clause 8.4 repeats it at planned intervals or when significant changes are proposed. ISO/IEC 42005:2025 gives detailed guidance on running these assessments, though ISO/IEC 42001 predates it and does not cite it. Triggers, thresholds and sign-off are covered under the AI impact assessment.

A.6 AI system life cycle

Nine controls under two objectives make A.6 the largest area. A.6.1 sets the objectives and processes for responsible development. A.6.2 then walks the life cycle: requirements, design records, verification and validation, deployment, operation and monitoring, technical documentation and event logs.

Evidence for A.6 lives in engineering tools. Tickets, pull requests, evaluation reports, release approvals and monitoring alerts become the records an auditor reads. Auditors often trace one system end to end, from a requirement to its test result to a live monitoring alert. If those records sit in three tools with no shared ID, the trace breaks.

Builders and buyers differ here, because a team that only buys AI usually keeps deployment, operation and logging and justifies the build controls. For A.6.2.8, decide which life cycle phases keep event logs, with at least the period of use covered. ISO/IEC 24970 on AI system logging was still at the final draft ballot stage, unpublished, when GAICC checked iso.org on 6 October 2026.

A.7 Data for AI systems

Data used to build and run AI systems falls under A.7, which covers management, acquisition, quality, provenance and preparation. ISO/IEC 42001 defines data quality as data meeting the organization’s own requirements for a specific context. The A.7.4 requirement therefore starts with written quality criteria, and tooling comes after them.

Retrieval sources count. A document store behind a chatbot, or a library of example prompts, is data going into the system. One practitioner on a public AI governance forum placed such a library in both A.7 and A.6, since it is also a built component. Provenance under A.7.5 is where most teams lack records, especially for older datasets bought or scraped before anyone asked where they came from. Field-level guidance, including the ISO/IEC 5259 data quality series, sits in data controls under A.7.

A.8 Information for interested parties

Disclosure is the theme of A.8: what you tell users and other interested parties about your AI systems. Its four controls cover user information, a route for outside reports of adverse impacts, and incident communication. The fourth covers reporting duties to others, such as regulators or customers.

A.8.4 reaches beyond the security incident plan. A model that starts producing biased loan letters is an AI incident even when no data has leaked. The communication plan should name who decides to notify users, what triggers it and which template applies. A.8.5 works best as a register of obligations by audience, maintained with legal, because customer contracts often add reporting duties that no regulation imposes on its own.

A.9 Use of AI systems

Responsible use by the organization itself is the subject of A.9: use processes, use objectives and intended use. Almost every organization in scope needs these controls, including one that builds nothing. For buyers, A.9 and A.10 usually carry most of the risk treatment.

A.9.4 catches shadow AI. Staff who paste client files into a public chatbot are using an AI system outside its intended use. Evidence for A.9 therefore mixes rules with signals: an acceptable use procedure, usage monitoring, and records of exceptions granted or refused. Use objectives under A.9.3 connect to the AI objectives that clause 6.2 asks you to plan and measure.

A.10 Third-party and customer relationships

A.10 covers responsibilities shared with partners, suppliers and customers. A.10.2 splits life cycle duties, A.10.3 checks suppliers against your responsible AI approach, and A.10.4 takes customer needs into account.

A supplier’s certificate stops at the supplier’s boundary. Microsoft’s ISO/IEC 42001 compliance page makes the point directly: customers still have to bring in their own assessor for the controls inside their own organization. File the certificate as supplier evidence, then assess the use you make of the service. Contract clauses carry most A.10 evidence: model change notice, incident notice, data use limits and audit rights. The vendor assessment method is set out in third-party AI supplier controls.

What Annex B, C and D add to the controls

Annex B of ISO/IEC 42001 is normative implementation guidance with one section for each Annex A control, numbered to match. Clause 6.1.3 asks you to consider it when you decide how to implement a control. Annex B is where control topics get concrete, such as what to record about data resources or which groups an impact assessment should consider.

Annex C is informative and lists candidate AI objectives, from accountability and fairness to transparency and explainability. It also lists risk sources, such as level of automation and system life cycle issues. The objectives feed clause 6.2 and the risk sources feed clause 6.1.2. Annex D is also informative. It covers using the AIMS across sectors and integrating it with other management system standards.

How Annex A relates to ISO/IEC 27001 Annex A

ISO/IEC 42001 Annex A and ISO/IEC 27001 Annex A share a role and differ in subject. Both are reference control sets that the Statement of Applicability is checked against. The 27001:2022 set holds 93 information security controls in four themes. The 42001 set holds 38 AI controls over nine areas and gives impact assessment an area of its own.

Three structural differences matter for a team that runs both. First, 27001 keeps its control guidance in a companion standard, ISO/IEC 27002, while 42001 keeps it inside Annex B. Second, 27001 clause 6.1.3 asks the Statement of Applicability to show whether every needed control has been put in place. Public reproductions of 42001 clause 6.1.3 do not list that element, although an implementation status column is still good practice. Third, 42001 lets roles shape applicability far more than 27001 does. The control-by-control carry-over is mapped in how the two Annex A sets compare in practice.

Mapping Annex A to the NIST AI RMF

A crosswalk listed on NIST’s AI Resource Center maps NIST AI RMF subcategories to ISO/IEC 42001 clauses and Annex B guidance sections. Three caveats apply. Microsoft provided the crosswalk. It maps the final draft of 42001 instead of the published text, and NIST states that listing a crosswalk does not imply endorsement. The rows below are taken from that crosswalk; B numbers mirror the Annex A control numbers.

NIST AI RMF subcategory (theme)Main Annex B sections the crosswalk maps it to (selection)
GOVERN 1.6 (inventory of AI systems)B.4.2 to B.4.6
GOVERN 2.1 (roles and lines of communication)B.3.2, with clause 5.3
GOVERN 6.1 and 6.2 (third-party risk and contingency)B.10.2 and B.10.3
MAP 2.3 (scientific integrity and TEVV, including data)B.7.2 to B.7.6, with B.6.1.3 and B.6.2.7
MEASURE 2.6 (regular safety evaluation)B.6.2.8, with B.6.2.4 and B.6.2.6
MANAGE 1.1 (whether the system meets its intended purpose)B.9.2 to B.9.4

A team that already reports against the NIST AI RMF 1.0 can reuse evidence through these rows, after checking each mapping against the published 42001 text. The full list sits with the other crosswalks on NIST’s AI Resource Center.

Other control sets map to Annex A too. Version 1.1 of the Cloud Security Alliance’s AI Controls Matrix, out since June 2026, has 247 control objectives in 18 domains and a mapping to ISO/IEC 42001. Cloud teams use it to find technical controls that sit below the level of an Annex A line.

What auditors do with Annex A

Certification auditors use Annex A as the frame for testing your control set, and they read the reasons behind each selection before sampling the controls themselves. ISO/IEC 42006 sets rules for AIMS certification bodies. Its final draft requires the audit team, taken together, to cover knowledge of all Annex A controls and their implementation. At Stage 1 the auditor reads the Statement of Applicability and its reasons. At Stage 2 the auditor samples records to see whether the selected controls operate in practice.

The strongest preparation is a trace you can show on demand: a risk, the control chosen to treat it, the owner, and three recent records. One ISO/IEC 27001 practitioner on a public forum named weak mapping of risks back to Annex A controls as one of two findings that come up time after time. The same weakness carries straight into ISO/IEC 42001 audits. GAICC’s Lead Implementer training on selecting and evidencing controls practices that trace, with modules on clause 6 planning and on Stage 1 and Stage 2 audits.

[TRAINER INSIGHT NEEDED: Which Annex A control do GAICC instructors see implementers struggle most to evidence at Stage 2, and what record finally satisfied the auditor?]

Where to start, by your situation

Annex A work starts in different places depending on your role and existing systems.

  • Organizations that only buy AI begin with A.9, A.10 and A.5, then build the A.4 register. Most A.6 build controls will need a recorded justification in place of an implementation.
  • Teams that build or fine-tune models carry the most evidence in A.6 and A.7, so dataset and model records belong under version control from the first sprint.
  • An organization already certified to ISO/IEC 27001 can reuse document control, internal audit and supplier review, then add the AI-specific controls. Check where the Statement of Applicability sits within the documentation set.
  • Anyone mapping clauses against controls can pair this register with what the implementer produces, clause by clause.
  • Program leads planning the whole rollout should sequence the controls inside the wider work of implementing an AIMS.
  • Lead Implementer exam candidates should learn the nine area titles, the two A.6 objectives and the selection logic in clause 6.1.3. Practice reasoning about applicability instead of memorizing control numbers. GAICC’s 42001 control implementation course pairs that material with an exam simulator.

Frequently asked questions

How many controls are there in ISO 42001?

Annex A of ISO/IEC 42001:2023 lists 38 controls under ten control objectives in nine areas, A.2 to A.10. A.6, the AI system life cycle, is the largest area with nine controls, and each control has a matching guidance section in Annex B. Confirm the wording of every control against a licensed copy before you build your register.

Is Annex A mandatory in ISO 42001?

Annex A is normative, so the comparison step in clause 6.1.3 is required and the Statement of Applicability must justify every inclusion and exclusion. Individual controls are not automatically required, and the note to the 3.26 definition says you may need fewer or more. Whether any organization is obliged to adopt ISO/IEC 42001 itself is a separate matter, taken up in what ISO 42001 solves for US organizations.

Is there an ISO 42001 controls list in Excel?

ISO sells ISO/IEC 42001 as a PDF or paper document, and its iso.org page lists no spreadsheet edition. The standard’s copyright notice bars reproducing its text without permission, which is why the register on this page carries only IDs, short titles and GAICC’s own paraphrase. Those columns can be copied into a spreadsheet as the starting point for your Statement of Applicability.

Can you fail a certification audit over an Annex A control?

Yes, if an included control does not operate or an exclusion has no traceable reason. Either gap gives the auditor grounds for a nonconformity under 6.1.3, or under 8.3, which requires the treatment plan to be carried out and verified. Stage 2 is where such gaps show, because the auditor samples records to see whether the selected controls operate.

Does every Annex A control need its own procedure?

Not necessarily. One document can serve several controls: a single AI policy usually covers both A.2.2 and clause 5.2, even though some controls, such as A.5.3 on impact assessment results, ask for specific records. The list of documents the standard requires is set out in the ISO 42001 documentation guide.

How often should the Annex A selection be reviewed?

Review the selection whenever the risk assessment reruns, which clause 8.2 requires at planned intervals and on significant change. Clause 8.3 then sends any new risk back through the 6.1.3 treatment process. Typical triggers are a new AI system, a change of role or a new supplier model, and each SoA version stays under document control.

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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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