Security Lights the Way

Crossbearing · standards comparison

ISO/IEC 42001 to ISO/IEC 27001

What you can reuse, what to extend and what is new when you add ISO/IEC 27001 to ISO/IEC 42001.

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What carries over from ISO/IEC 42001 to ISO/IEC 27001

Your AIMS gives you the management system; ISO/IEC 27001 adds the security. The shared clauses carry over, but the 93 controls in ISO/IEC 27001 Annex A reach far beyond AI, and only a handful have counterparts in your AI controls.

Of the 118 clauses and controls ISO/IEC 27001 asks for: 9 to reuse, 29 to extend and 80 new.

  • 9 Reuse Use what you have: the same process or document, with its scope widened.
  • 29 Extend Keep what you have and add the new standard’s content.
  • 80 New Nothing you have covers it: new work.

Clause and control numbers checked against ISO/IEC 42001 and ISO/IEC 27001 themselves; descriptions are MajorCyber™’s own words. Mapping by MajorCyber™, last checked 23 October 2026. Going the other way? ISO/IEC 27001 to ISO/IEC 42001

Do I need to rewrite my policies?

No. Keep your AI policy and the framework it sits in. Add an information security policy, and the topic-specific security policies your risks call for — access control, cryptography, supplier security and so on — under the same approval and review process.

The management system, clause by clause

Both follow the harmonised structure that ISO management-system standards share, so clauses 4 to 10 line up by number. Each row says what ISO/IEC 27001 asks for and what to do with what your AIMS already has.

Clause Your ISO/IEC 42001 ISO/IEC 27001 asks for What to do
4.1 Context Issues that affect the AIMS, including whether climate change is relevant; the intended purpose of the AI systems the organisation develops, provides or uses; and its role for each — provider, producer, customer, partner and so on. Internal and external issues that affect what the ISMS is meant to achieve — including, since the 2024 amendment, whether climate change is relevant. Extend Add the information security issues to the context you already analyse.
4.2 Interested parties Who has a stake in the organisation’s AI, what they require, and which of those requirements the AIMS will address. Who has a stake in information security, what they require, and which of those requirements the ISMS will address. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
4.3 Scope The boundaries of the AIMS, taking account of the AI systems and activities it covers. The boundaries of the ISMS: which parts of the organisation, locations, assets and interfaces it covers. Extend Write the ISMS scope: which parts of the organisation, sites and assets it covers. It is usually wider than the AI systems.
4.4 The management system An AIMS that is set up, run, maintained and continually improved, with its processes and how they interact. An ISMS that is set up, run, maintained and continually improved, with its processes and how they interact. Reuse Use your AIMS’s process for both systems, with its scope widened to the ISMS.
5.1 Leadership Top management directs and supports the AIMS: aligned with strategy, built into the business, resourced and communicated. Top management directs and supports the ISMS: aligned with strategy, built into the business, resourced and communicated. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
5.2 Policy An AI policy that fits the organisation’s purpose, frames AI objectives and commits to meeting requirements and improving. An information security policy from top management that frames objectives and commits to meeting requirements and improving. New An information security policy, beside the AI policy or as a clearly marked part of an integrated one.
5.3 Roles Responsibilities and authorities for the AIMS assigned and communicated. Responsibilities and authorities for information security assigned and communicated. Extend Add information security roles to those you already assign.
6.1.1 Risks and opportunities Plan how the AIMS addresses its risks and opportunities, with criteria that tell acceptable AI risks from unacceptable ones. Plan how the ISMS addresses the risks and opportunities that come from its context and interested parties. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
6.1.2 Risk assessment An AI risk assessment process, informed by the AI policy and objectives, that takes the results of AI system impact assessments into account. A repeatable information security risk assessment: criteria for acceptance and assessment, risk owners, likelihood and consequence, prioritisation. Extend Keep one risk method, and extend it to information security: confidentiality, integrity and availability of the information in scope, with named risk owners.
6.1.3 Risk treatment Choose treatments and controls, with Annex A as a reference, write a Statement of Applicability (6.1.3 f) and an AI risk treatment plan approved by designated management. Choose treatments and the controls they need, compare them with Annex A, write a Statement of Applicability (6.1.3 d) and a treatment plan approved by the risk owners. Extend Keep one treatment process, but write a separate Statement of Applicability against the 93 controls of ISO/IEC 27001 Annex A, with a treatment plan approved by the risk owners.
6.2 Objectives AI objectives, with plans for who achieves them, how and by when. Measurable information security objectives, with plans for who achieves them, how and by when. Extend Add measurable security objectives to those you already track.
6.3 Planning changes Changes to the management system are carried out in a planned way. Changes to the management system are carried out in a planned way. Reuse Use your AIMS’s process for both systems, with its scope widened to the ISMS.
7.1 Resources The resources the management system needs are provided. The resources the management system needs are provided. Reuse Use your AIMS’s process for both systems, with its scope widened to the ISMS.
7.2 Competence People whose work affects AI performance are competent, with evidence kept. People whose work affects information security are competent, with evidence kept. Extend Add security competences to the framework and its records.
7.3 Awareness People know the AI policy, their part in the AIMS, and what not following it means. People know the security policy, their part in the ISMS, and what failing to follow it means. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
7.4 Communication What is communicated, when, to whom and how. What is communicated, when, to whom and how. Reuse Use your AIMS’s process for both systems, with its scope widened to the ISMS.
7.5 Documented information Documents and records the AIMS needs are created, updated and controlled. Documents and records the ISMS needs are created, updated and controlled. Reuse Use your AIMS’s process for both systems, with its scope widened to the ISMS.
8.1 Operational control Processes planned, run and controlled, including outsourced ones, with evidence that they ran as planned. Processes planned, run and controlled, including outsourced ones, with evidence that they ran as planned. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
8.2 Risk assessment in operation AI risk assessments carried out at planned intervals and when significant changes happen. Risk assessments carried out at planned intervals and when significant changes happen. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
8.3 Risk treatment in operation The AI risk treatment plan implemented, and its effectiveness checked. The risk treatment plan implemented. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
9.1 Monitoring and measurement What is monitored and measured, how and when, and how the results are evaluated. What is monitored and measured, how and when, and how the results are evaluated. Extend Keep what your AIMS has here, and add what ISO/IEC 27001 asks for.
9.2 Internal audit Internal audits at planned intervals, by objective auditors, against the standard and the organisation’s own requirements. Internal audits at planned intervals, by objective auditors, against the standard and the organisation’s own requirements. Reuse Keep one audit procedure. Widen the audit programme to the ISMS and its 93 controls.
9.3 Management review Top management reviews the AIMS at planned intervals, with set inputs and recorded decisions. Top management reviews the ISMS at planned intervals, with set inputs and recorded decisions. Reuse One management review can cover both, if it takes each standard’s required inputs and records decisions for each system.
10.1 Continual improvement The AIMS keeps getting more suitable, adequate and effective. The ISMS keeps getting more suitable, adequate and effective. Reuse Use your AIMS’s process for both systems, with its scope widened to the ISMS.
10.2 Nonconformity and corrective action Nonconformities are corrected, their causes found and removed, and the actions checked. Nonconformities are corrected, their causes found and removed, and the actions checked. Reuse Use your AIMS’s process for both systems, with its scope widened to the ISMS.

Controls: ISO/IEC 27001 Annex A, against ISO/IEC 42001 Annex A

ISO/IEC 42001 is not a security standard, so most of ISO/IEC 27001 Annex A is new work from an AIMS. The rows below show where your AI controls give you a start.

ISO/IEC 27001 control Supported by your ISO/IEC 42001 What to do
Organisational
5.1 Security policy set, approved and kept under review
  • A.2.2 A documented policy for developing or using AI Partly covers it
  • A.2.4 AI policy reviewed at planned intervals Partly covers it
  • A.2.3 Other policies aligned with the AI objectives Related
Extend The AI policy’s approval and review process can carry the security policy set; the security policies themselves are new.
5.2 Security roles and responsibilities assigned
  • A.3.2 Roles and responsibilities for AI Partly covers it
Extend Add information security roles to the responsibilities you already assign.
5.3 Conflicting duties kept apart No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.4 Managers require staff to follow security policy No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.5 Contacts with the relevant authorities No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.6 Links with security forums and specialist groups No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.7 Threat intelligence gathered and used No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.8 Security built into projects No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.9 Inventory of information and assets, with owners
  • A.4.2 Resources for AI activities documented Partly covers it
  • A.4.3 Data resources documented Partly covers it
  • A.4.4 Tooling resources documented Partly covers it
  • A.4.5 System and computing resources documented Partly covers it
Extend Your AI resource records are a start; the inventory covers all information and associated assets, each with an owner.
5.10 Rules for acceptable use of information and assets
  • A.9.2 Processes for responsible use Partly covers it
  • A.9.4 Use kept to the intended purpose Related
Extend Responsible-use rules for AI become part of acceptable use for all information and assets.
5.11 Assets handed back when people leave No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.12 Information classified by sensitivity
  • A.7.2 Data management for development and enhancement Related
New AI data management helps; classify all information by sensitivity.
5.13 Information labelled to match its classification No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.14 Rules for transferring information No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.15 Access control rules No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.16 Identities managed through their life cycle No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.17 Passwords and other secrets managed No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.18 Access rights granted, reviewed and removed No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.19 Security in supplier relationships
  • A.10.2 Responsibilities shared across the AI supply chain Partly covers it
Extend Shared AI responsibilities help; security in supplier relationships covers every supplier with access to your information.
5.20 Security terms in supplier contracts
  • A.10.3 Suppliers of AI services, products and data Partly covers it
Extend AI supplier checks carry over; put security terms into every supplier contract.
5.21 Security across the ICT supply chain
  • A.10.3 Suppliers of AI services, products and data Related
New AI suppliers are part of the wider ICT supply chain, which needs security too.
5.22 Supplier services monitored and reviewed No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.23 Security for the cloud services you use No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.24 Incident management planned and prepared
  • A.8.4 A plan to tell users about incidents Partly covers it
Extend Communicating AI incidents is a start; incident management covers planning, roles and procedures for all security incidents.
5.25 Security events assessed and classified No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.26 Incidents responded to by procedure No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.27 Lessons from incidents applied No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.28 Evidence collected and preserved No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.29 Security kept up during disruption No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.30 ICT ready for business continuity No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.31 Legal, regulatory and contractual requirements identified
  • A.8.5 Information owed to interested parties Partly covers it
  • A.10.4 Customers’ needs and expectations met Related
Extend Your AI reporting obligations become part of a wider register of legal, regulatory and contractual requirements.
5.32 Intellectual property respected
  • A.7.3 How data is acquired and selected Related
New Data licensing checks help; cover software licences and other intellectual property too.
5.33 Records protected No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.34 Privacy and personal data protected
  • A.5.4 Impacts on individuals and groups assessed Related
New AI impact assessments touch personal data; protecting privacy and PII needs controls of its own.
5.35 Independent review of security No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.36 Compliance with security policies checked No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
5.37 Operating procedures documented
  • A.6.2.7 Technical documentation for those who need it Related
New Technical documentation helps; document operating procedures for every system that handles information.
People
6.1 Background checks before people join No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
6.2 Security duties in terms of employment No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
6.3 Security awareness, education and training
  • A.4.6 People and their competences documented Related
New AI competence records help; security awareness and training must reach everyone in scope.
6.4 Disciplinary process for policy breaches No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
6.5 Duties that continue after people leave or move No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
6.6 Confidentiality agreements No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
6.7 Remote working secured No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
6.8 Staff report security events
  • A.3.3 A way to raise concerns about AI systems Related
  • A.8.3 A channel to report adverse impacts Related
New A channel for concerns can be widened into security event reporting, with triage.
Physical
7.1 Secure perimeters No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.2 Entry controls No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.3 Offices, rooms and facilities secured No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.4 Premises monitored No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.5 Protection from physical and environmental threats No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.6 Rules for working in secure areas No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.7 Clear desks and locked screens No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.8 Equipment sited and protected No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.9 Assets protected off site No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.10 Storage media handled securely No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.11 Power and other utilities protected No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.12 Cabling protected No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.13 Equipment maintained No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
7.14 Equipment wiped before disposal or reuse No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
Technological
8.1 User devices protected No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.2 Privileged access restricted No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.3 Access to information restricted No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.4 Access to source code controlled No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.5 Secure authentication No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.6 Capacity managed No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.7 Malware protection No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.8 Technical vulnerabilities managed No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.9 Configurations managed No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.10 Information deleted when no longer needed No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.11 Data masking
  • A.7.6 Data preparation criteria Related
New Data preparation may include masking; apply masking by policy wherever data is sensitive.
8.12 Data leakage prevented No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.13 Backups No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.14 Redundancy for availability No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.15 Logging
  • A.6.2.8 Event logs while AI systems are in use Partly covers it
Extend AI event logs are a start; logging covers every system, with logs protected and reviewed.
8.16 Monitoring for anomalous behaviour
  • A.6.2.6 Operation and monitoring Partly covers it
Extend Model monitoring helps; security monitoring looks for anomalous behaviour across networks and systems.
8.17 Clocks synchronised No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.18 Powerful utility programs restricted No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.19 Software installation on live systems controlled No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.20 Networks secured No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.21 Network services secured No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.22 Networks segregated No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.23 Web filtering No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.24 Cryptography and key management No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.25 Secure development life cycle
  • A.6.1.3 Processes for responsible design and development Partly covers it
  • A.6.1.2 Objectives for responsible development Related
Extend Your responsible-AI development process is the frame; add security activities at each stage.
8.26 Security requirements for applications
  • A.6.2.2 Requirements and specifications for AI systems Partly covers it
Extend Add security requirements to the AI requirements you already specify.
8.27 Secure architecture and engineering principles
  • A.6.2.3 Design and development documented Related
New Add secure architecture and engineering principles to the design documentation.
8.28 Secure coding No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.29 Security testing before release
  • A.6.2.4 Verification and validation Partly covers it
Extend Add security testing to AI verification and validation.
8.30 Outsourced development overseen No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.31 Development, test and live environments kept apart No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.32 Changes controlled
  • A.6.2.5 Deployment planned and checked Partly covers it
Extend Deployment planning helps; change control covers every change to information systems.
8.33 Test data protected No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.
8.34 Audit testing that protects live systems No counterpart New Nothing in ISO/IEC 42001 Annex A corresponds: new work.

What to do with each document

The documented information ISO/IEC 27001 requires, and what to do with yours. Tick each one off as you go: the ticks are kept in this browser only.

A route from ISO/IEC 42001 to ISO/IEC 27001

  1. Scope

    • Set the ISMS scope: the parts of the organisation, sites and information it covers
    • Decide how it relates to the AIMS scope

  2. Gap assessment

    • Go through this page clause by clause
    • Check the 93 controls of ISO/IEC 27001 Annex A against what you run today

  3. Governance

    • An information security policy approved by top management
    • Security roles assigned
    • Measurable security objectives

  4. Risk

    • Extend the risk method to information security, with risk owners
    • Treat the risks and write the Statement of Applicability against ISO/IEC 27001 Annex A

  5. Controls

    • Implement the organisational, people, physical and technological controls your risks need
    • Extend the inventory, supplier and development processes you already run for AI

  6. Run and check

    • Operate the ISMS and keep its records
    • An internal audit that covers the ISMS
    • A management review with the ISMS inputs

  7. Certification

    • Ask your certification body about a combined audit with ISO/IEC 42001
    • Line up the audit cycles of both certificates

Certification and audits

  • The certificates stay separate: one for ISO/IEC 42001, one for ISO/IEC 27001, each against its own standard and scope.
  • Ask your certification body about auditing both management systems together, and check it is accredited for ISO/IEC 27001.
  • Line up the surveillance and recertification dates so that one audit cycle covers both.

Common pitfalls

  • Assuming the AI controls cover information security: most of the 93 controls in ISO/IEC 27001 Annex A have no AI counterpart.
  • Scoping security to the AI systems only, when the ISMS covers all the information in its scope.
  • No named risk owners: ISO/IEC 27001 asks for them.
  • Forgetting the people and physical controls.

ISO/IEC 42001 and ISO/IEC 27001 at a glance

ISO/IEC 42001 ISO/IEC 27001
What it is Certifiable standard Certifiable standard
How it applies Voluntary, often required by customers Voluntary, often required by customers
How you show it Certification by an accredited certification body Certification by an accredited certification body
Where International International
Covers AI governance, Risk management, Audit & assurance Information security, Risk management, Audit & assurance
Issued or enforced by ISO and IEC (ISO/IEC JTC 1/SC 42 Artificial intelligence) ISO and IEC (joint technical committee ISO/IEC JTC 1/SC 27)
Current edition or status ISO/IEC 42001:2023, first edition (December 2023). Supporting standards include ISO/IEC 42005 (impact assessment) and ISO/IEC 42006 (certification bodies). ISO/IEC 27001:2022, amended by ISO/IEC 27001:2022/Amd 1:2024 (climate change considerations). The 2013 edition's certification transition has ended.

Next steps on MajorCyber™

Sources

An educational comparison, researched and drafted with AI assistance. A mapping shows where work you have already done supports a requirement; it never means the requirement is met. Your certification body decides what conforms. No standard’s text is reproduced: buy the standards from ISO or your national standards body.