Breaking Down ISO 42001 Annex A: The Controls Behind Responsible AI
Artificial intelligence is moving fast, and so are the expectations around how it is governed.
ISO/IEC 42001:2023 is the world’s first management system standard for AI. At its core is Annex A—a detailed framework of nine control objectives and 38 specific controls that organizations can adopt to build, deploy, and use AI responsibly.
For businesses in regulated industries, Annex A is a practical blueprint for managing risk, building trust, and ensuring AI systems deliver value without unintended harm.
What Annex A Covers
Annex A lays out the reference control objectives and controls that form the foundation of an AI Management System (AIMS).
- 9 Control Objectives (A.2 through A.10)
- 38 Specific Controls across policy, organization, lifecycle, data, transparency, use, and third-party relationships
Together, they provide a structured way to govern AI across its full lifecycle—from design and data acquisition to deployment, monitoring, and retirement.
The Nine Control Objectives
Each objective represents a critical area of governance:
- A.2 → Policies Related to AI
Set clear policies for AI use that align with business and ethical requirements. - A.3 → Internal Organization
Define accountability and create ways for employees and stakeholders to raise concerns. - A.4 → Resources for AI Systems
Manage the people, data, tools, and computing resources needed for responsible AI. - A.5 → Assessing Impacts of AI Systems
Evaluate potential impacts on individuals, groups, and society before deployment. - A.6 → AI System Life Cycle
Apply structured processes to design, develop, deploy, monitor, and retire AI systems. - A.7 → Data for AI Systems
Ensure training and operational data are acquired legally, documented properly, and checked for quality and provenance. - A.8 → Information for Interested Parties
Provide transparency to users, customers, regulators, and other stakeholders. - A.9 → Use of AI Systems
Govern how AI systems are used, ensuring alignment with intended purposes and guardrails. - A.10 → Third-Party and Customer Relationships
Manage supplier risk and make sure customers understand the role and limitations of AI systems.
The 38 Controls in Practice
Annex A breaks each objective into actionable controls. Examples include:
- AI Policy: Establish and regularly update a policy that defines responsible AI principles.
- Roles and Responsibilities: Assign clear ownership for AI design, validation, and oversight.
- Impact Assessments: Document how systems may affect individuals, groups, or society at large.
- Verification and Validation: Test systems to ensure they meet safety, fairness, and performance requirements.
- Event Logs: Maintain detailed logs for accountability and auditing.
- Data Provenance: Track where data comes from and how it has been processed.
- Incident Communication: Create processes to report AI failures or unexpected outcomes.
- Supplier Management: Conduct due diligence on third parties providing AI components or services.
- Customer Transparency: Provide information on how AI is used and its limitations.
Each control reinforces responsible practices, ensuring AI is managed like any other business-critical system—with documentation, oversight, and continuous improvement.
Why SMBs need Annex A
For many small and mid-sized organizations, AI feels like a double-edged sword: essential for competitiveness, but risky without proper governance.
Annex A provides a roadmap to:
- Reduce Risk: Identify and mitigate issues such as bias, misuse, or drift before they cause harm.
- Build Trust: Demonstrate to customers, partners, and regulators that AI systems are safe, transparent, and accountable.
- Stay Ahead of Regulation: Anticipate requirements from emerging AI laws, such as the EU AI Act, by aligning with ISO’s global standard.
- Enable Growth: Free leadership to focus on innovation, knowing AI systems are managed responsibly.
How to Put Annex A Into Action
- Start with a Gap Analysis
Compare current practices against Annex A controls to see where you stand. - Prioritize by Risk
Not every control carries the same urgency. Focus first on those tied to safety, data integrity, and stakeholder trust. - Assign Ownership
Define who is responsible for each control—whether that’s IT, compliance, legal, or product teams. - Document and Monitor
Many controls require documentation and ongoing monitoring. Build simple processes that scale over time. - Iterate
Revisit your approach as AI evolves and regulatory expectations change. Annex A is designed for continuous improvement.
The Bottom Line
Adopting Annex A practices helps SMBs reduce risk, demonstrate accountability, and align with emerging regulations. It creates a clear framework for managing AI responsibly and with confidence.
Implementing it can be challenging without the right support. Deepsight has the expertise to make it practical and achievable for your organization.
Schedule a call with Deepsight.