A.3.2·high·Component: Organizational controlsWhat this control requires
Roles, responsibilities, and accountability for AI governance and operations shall be defined, assigned, and maintained.
In plain English
Roles, responsibilities, and accountability for AI governance and operations shall be defined, assigned, and maintained. In practice, this means you can prove you define governance-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.3.2) 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.
- Govern. Document the trigger, the owner and the cadence.
- Scope: governance.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
- Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
Approved AI governance policies define AI roles, responsibilities, and accountability. Identity and access evidence should verify assigned role ownership, authorization boundaries, and periodic review of privileged responsibilities. Focus: AI roles and responsibilities.
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.5.16 — Identity management
- ISO/IEC 27701:2025 A.3.8 — Identity management
- CIS Controls v8 6.1 — Establish an Access Granting Process
- SOC 2 (2017 TSC) CC1.5 — Accountability for Internal Control Responsibilities
- NIST SP 800-171 Rev. 3 3.13.4 — Information in Shared System Resources
Related controls in ISO/IEC 42001:2023
- Annex A A.4.6 — Human resources
- Annex A A.2.3 — Alignment with other organizational policies
- Annex A A.9.2 — Processes for responsible use of AI systems
- Annex A A.9.3 — Objectives for responsible use of AI systems
References
- ISO/IEC JTC 1/SC 42 — ISO/IEC 42001:2023
- Catalogue identifier:
Annex A A.3.2
Topics: governance riskidentity accessaccess controlidentity managementaccess review