A.10.4·high·Component: Organizational controlsWhat this control requires
Customer-related AI obligations shall be defined and managed, including transparency, support, and incident handling responsibilities.
In plain English
Customer-related AI obligations shall be defined and managed, including transparency, support, and incident handling responsibilities. In practice, this means you can prove you define customers-level controls on a defined cadence.
Why it matters
ISO 42001 is the first audited evidence regulators, customers and investors can ask for that you are managing AI risk. Each Annex A control is a check-box in that audit; it is also the management system enterprises are starting to require from AI vendors before an MSA can be signed.
This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.
What an auditor looks for
An ISO 42001 auditor verifies you have an AI policy, a risk-based system of impact assessments for each AI system, lifecycle controls from data acquisition through retirement, and third-party-AI controls that pierce the vendor's wrapper to underlying model behaviour.
Within Organizational controls, the assessor will trace your implementation back to the catalogue reference (Annex A A.10.4) and look for objective evidence on the latest two assessment cycles.
How to implement
- Write a short policy stating intent, scope and named owner.
- Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
- Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
- Review on a documented cadence and capture the review in the risk register or compliance tracker.
Operational checklist
- Define. Document the trigger, the owner and the cadence.
- Manage. Document the trigger, the owner and the cadence.
- Scope: customers.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
- Ticketing Workflow.
ticketing_workflowevidence
Policies and workflow evidence should demonstrate how customer-related AI obligations, support expectations, transparency, and incident handling responsibilities are defined and managed. Focus: Customers.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- ISO/IEC 27001:2022 A.5.19 — Information security in supplier relationships
- SOC 2 (2017 TSC) CC9.2 — Vendor Risk Management
- GDPR Article 28 — Processor
- ISO/IEC 27701:2025 A.3.10 — Supplier agreements
Related controls in ISO/IEC 42001:2023
References
- ISO/IEC JTC 1/SC 42 — ISO/IEC 42001:2023
- Catalogue identifier:
Annex A A.10.4
Topics: third party riskcustomer obligationsgovernance riskvendor managementthird party monitoringsupply chain security