A.2.2·high·Component: Organizational controlsWhat this control requires
Policies shall be defined, approved, and communicated to govern responsible development, provision, and use of AI systems across the organization.
In plain English
Policies shall be defined, approved, and communicated to govern responsible development, provision, and use of AI systems across the organization. In practice, this means you can prove you define ai systems-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.2.2) and look for objective evidence on the latest two assessment cycles.
How to implement
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
Operational checklist
- Define. Document the trigger, the owner and the cadence.
- Communicate. Document the trigger, the owner and the cadence.
- Develop. Document the trigger, the owner and the cadence.
- Govern. Document the trigger, the owner and the cadence.
- Use. Document the trigger, the owner and the cadence.
- Scope: ai systems, policies.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Approved AI governance policies define management direction, responsibilities, and decision-making expectations for the responsible development, provision, and use of AI systems. Evidence should demonstrate current approval status, ownership, communication, and version control. Focus: Policies for the responsible development or use of AI systems.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
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.5.5 — Contact with authorities
- ISO/IEC 27701:2025 A.3.3 — Information security policies
- NIST SP 800-53 Rev. 5 CP-7(4) — Preparation For Use
- CIS Controls v8 2.6 — Allowlist Authorized Libraries
- SOC 2 (2017 TSC) CC2.3 — External Communication on Internal Control Matters
Related controls in ISO/IEC 42001:2023
- Annex A A.2.4 — Review of policies for responsible AI
- Annex A A.2.3 — Alignment with other organizational policies
- Annex A A.8.2 — System documentation and information for users
- Annex A A.9.4 — Intended use of AI systems
- Annex A A.3.3 — Reporting of concerns
- Annex A A.8.3 — External reporting
References
- ISO/IEC JTC 1/SC 42 — ISO/IEC 42001:2023
- Catalogue identifier:
Annex A A.2.2
Topics: governance riskpolicy management