Crossbearing · standards comparison
NIST AI RMF to ISO/IEC 42001
What you can reuse, what to extend and what is new when you add ISO/IEC 42001 to NIST AI RMF.
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What carries over from NIST AI RMF to ISO/IEC 42001
A good share carries over, but as raw material. Your AI RMF outcomes map onto most of ISO/IEC 42001, yet the standard asks for an audited management system: a scope, an AI policy, objectives, documented processes, internal audit, management review and a Statement of Applicability. That system, and the evidence it produces, is the new work.
Of the 65 clauses and controls ISO/IEC 42001 asks for: 62 to extend and 3 new.
- 62 Extend Keep what you have and add the new standard’s content.
- 3 New Nothing you have covers it: new work.
Do I need to rewrite my policies?
Probably, at least in part. ISO/IEC 42001 requires an AI policy approved by top management, with commitments of its own, and documented processes for risk, impact assessment and the AI life cycle. Turn the practices your AI RMF profile describes into those documents rather than starting again.
The management system, clause by clause
ISO/IEC 42001 is a management-system standard with clauses 4 to 10; NIST AI RMF isn’t. Each row says what ISO/IEC 42001 asks for, and which parts of NIST AI RMF already support it.
| Clause | Your NIST AI RMF | ISO/IEC 42001 asks for | What to do |
|---|---|---|---|
| 4.1 Context | GOVERN 1.1MAP 1.3MAP 1.4MAP 4.1 | 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. | Extend Your GOVERN 1.1 work supports clause 4.1. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 4.2 Interested parties | Nothing here | Who has a stake in the organisation’s AI, what they require, and which of those requirements the AIMS will address. | New Nothing in NIST AI RMF corresponds: new work for the AIMS. |
| 4.3 Scope | MAP 3.3 | The boundaries of the AIMS, taking account of the AI systems and activities it covers. | Extend Your MAP 3.3 work supports clause 4.3. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 4.4 The management system | GOVERN 1.2MEASURE 3.1 | An AIMS that is set up, run, maintained and continually improved, with its processes and how they interact. | Extend Your GOVERN 1.2 work supports clause 4.4. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 5.1 Leadership | GOVERN 2.3MAP 1.4 | Top management directs and supports the AIMS: aligned with strategy, built into the business, resourced and communicated. | Extend Your GOVERN 2.3 work supports clause 5.1. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 5.2 Policy | GOVERN 1.2GOVERN 2.3MAP 1.3 | An AI policy that fits the organisation’s purpose, frames AI objectives and commits to meeting requirements and improving. | Extend Your GOVERN 1.2 work supports clause 5.2. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 5.3 Roles | GOVERN 2.1 | Responsibilities and authorities for the AIMS assigned and communicated. | Extend Your GOVERN 2.1 work supports clause 5.3. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 6.1.1 Risks and opportunities | GOVERN 1.3MAP 1.5MEASURE 1.1MANAGE 1.3MANAGE 2.3 | Plan how the AIMS addresses its risks and opportunities, with criteria that tell acceptable AI risks from unacceptable ones. | Extend Your GOVERN 1.3 work supports clause 6.1.1. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 6.1.2 Risk assessment | GOVERN 1.3GOVERN 1.4MAP 5.1MEASURE 1.1MEASURE 1.3MEASURE 2.8MANAGE 1.2MANAGE 1.3MANAGE 2.3 | An AI risk assessment process, informed by the AI policy and objectives, that takes the results of AI system impact assessments into account. | Extend Your GOVERN 1.3 work supports clause 6.1.2. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 6.1.3 Risk treatment | GOVERN 1.3GOVERN 1.4MANAGE 1.2MANAGE 1.3MANAGE 2.3 | 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. | Extend Your GOVERN 1.3 work supports clause 6.1.3. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 6.1.4 AI system impact assessment | GOVERN 4.2MAP 1.1MANAGE 1.2MANAGE 1.3 | A process for assessing the consequences an AI system’s use and foreseeable misuse could have for individuals, groups and society — documented, and fed into the risk assessment. | Extend Your GOVERN 4.2 work supports clause 6.1.4. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 6.2 Objectives | GOVERN 1.1MAP 1.3 | AI objectives, with plans for who achieves them, how and by when. | Extend Your GOVERN 1.1 work supports clause 6.2. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 6.3 Planning changes | Nothing here | Changes to the management system are carried out in a planned way. | New Nothing in NIST AI RMF corresponds: new work for the AIMS. |
| 7.1 Resources | GOVERN 2.1MANAGE 2.1MANAGE 2.2 | The resources the management system needs are provided. | Extend Your GOVERN 2.1 work supports clause 7.1. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 7.2 Competence | GOVERN 2.1GOVERN 2.2GOVERN 3.2MAP 1.2MAP 3.4 | People whose work affects AI performance are competent, with evidence kept. | Extend Your GOVERN 2.1 work supports clause 7.2. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 7.3 Awareness | GOVERN 2.1MAP 1.3 | People know the AI policy, their part in the AIMS, and what not following it means. | Extend Your GOVERN 2.1 work supports clause 7.3. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 7.4 Communication | GOVERN 2.1GOVERN 4.2MAP 1.3 | What is communicated, when, to whom and how. | Extend Your GOVERN 2.1 work supports clause 7.4. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 7.5 Documented information | MAP 1.3 | Documents and records the AIMS needs are created, updated and controlled. | Extend Your MAP 1.3 work supports clause 7.5. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 8.1 Operational control | Nothing here | Processes planned, run and controlled, including outsourced ones, with evidence that they ran as planned. | New Nothing in NIST AI RMF corresponds: new work for the AIMS. |
| 8.2 Risk assessment in operation | GOVERN 1.5MAP 3.2MEASURE 2.6MEASURE 3.1 | AI risk assessments carried out at planned intervals and when significant changes happen. | Extend Your GOVERN 1.5 work supports clause 8.2. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 8.3 Risk treatment in operation | GOVERN 1.4GOVERN 1.5MAP 3.2 | The AI risk treatment plan implemented, and its effectiveness checked. | Extend Your GOVERN 1.4 work supports clause 8.3. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 8.4 Impact assessment in operation | GOVERN 1.5MAP 3.2MEASURE 3.1 | AI system impact assessments carried out at planned intervals and when significant changes happen. | Extend Your GOVERN 1.5 work supports clause 8.4. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 9.1 Monitoring and measurement | GOVERN 2.1MEASURE 2.4MEASURE 4.1MEASURE 4.2 | What is monitored and measured, how and when, and how the results are evaluated. | Extend Your GOVERN 2.1 work supports clause 9.1. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 9.2 Internal audit | MEASURE 1.3MEASURE 4.2MANAGE 4.1 | Internal audits at planned intervals, by objective auditors, against the standard and the organisation’s own requirements. | Extend Your MEASURE 1.3 work supports clause 9.2. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 9.3 Management review | GOVERN 2.3MEASURE 4.3MANAGE 1.2MANAGE 4.2MANAGE 4.3 | Top management reviews the AIMS at planned intervals, with set inputs and recorded decisions. | Extend Your GOVERN 2.3 work supports clause 9.3. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 10.1 Continual improvement | MEASURE 3.2MANAGE 2.2 | The AIMS keeps getting more suitable, adequate and effective. | Extend Your MEASURE 3.2 work supports clause 10.1. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
| 10.2 Nonconformity and corrective action | MANAGE 2.3 | Nonconformities are corrected, their causes found and removed, and the actions checked. | Extend Your MANAGE 2.3 work supports clause 10.2. Turn it into the documented, auditable process ISO/IEC 42001 requires. |
Controls: ISO/IEC 42001 Annex A, against NIST AI RMF subcategories
Each ISO/IEC 42001 Annex A control, with the AI RMF subcategories that NIST’s crosswalk ties to it.
| ISO/IEC 42001 control | Supported by your NIST AI RMF | What to do |
|---|---|---|
| Policies for AI | ||
| A.2.2 A documented policy for developing or using AI |
| Extend Your GOVERN 1.1 work supports control A.2.2. Implement it as a control and record it in your Statement of Applicability. |
| A.2.3 Other policies aligned with the AI objectives |
| Extend Your MEASURE 2.7 work supports control A.2.3. Implement it as a control and record it in your Statement of Applicability. |
| A.2.4 AI policy reviewed at planned intervals |
| Extend Your GOVERN 1.1 work supports control A.2.4. Implement it as a control and record it in your Statement of Applicability. |
| Organisation | ||
| A.3.2 Roles and responsibilities for AI |
| Extend Your GOVERN 2.1 work supports control A.3.2. Implement it as a control and record it in your Statement of Applicability. |
| A.3.3 A way to raise concerns about AI systems |
| Extend Your MANAGE 2.2 work supports control A.3.3. Implement it as a control and record it in your Statement of Applicability. |
| Resources | ||
| A.4.2 Resources for AI activities documented |
| Extend Your GOVERN 1.6 work supports control A.4.2. Implement it as a control and record it in your Statement of Applicability. |
| A.4.3 Data resources documented |
| Extend Your GOVERN 1.6 work supports control A.4.3. Implement it as a control and record it in your Statement of Applicability. |
| A.4.4 Tooling resources documented |
| Extend Your GOVERN 1.6 work supports control A.4.4. Implement it as a control and record it in your Statement of Applicability. |
| A.4.5 System and computing resources documented |
| Extend Your GOVERN 1.6 work supports control A.4.5. Implement it as a control and record it in your Statement of Applicability. |
| A.4.6 People and their competences documented |
| Extend Your GOVERN 1.6 work supports control A.4.6. Implement it as a control and record it in your Statement of Applicability. |
| Impact assessment | ||
| A.5.2 A process for AI system impact assessment |
| Extend Your GOVERN 4.1 work supports control A.5.2. Implement it as a control and record it in your Statement of Applicability. |
| A.5.3 Impact assessments documented and kept |
| Extend Your GOVERN 3.2 work supports control A.5.3. Implement it as a control and record it in your Statement of Applicability. |
| A.5.4 Impacts on individuals and groups assessed |
| Extend Your GOVERN 3.1 work supports control A.5.4. Implement it as a control and record it in your Statement of Applicability. |
| A.5.5 Impacts on society assessed |
| Extend Your GOVERN 4.2 work supports control A.5.5. Implement it as a control and record it in your Statement of Applicability. |
| Life cycle | ||
| A.6.1.2 Objectives for responsible development |
| Extend Your GOVERN 1.2 work supports control A.6.1.2. Implement it as a control and record it in your Statement of Applicability. |
| A.6.1.3 Processes for responsible design and development |
| Extend Your GOVERN 1.2 work supports control A.6.1.3. Implement it as a control and record it in your Statement of Applicability. |
| A.6.2.2 Requirements and specifications for AI systems |
| Extend Your MAP 1.4 work supports control A.6.2.2. Implement it as a control and record it in your Statement of Applicability. |
| A.6.2.3 Design and development documented |
| Extend Your MAP 2.1 work supports control A.6.2.3. Implement it as a control and record it in your Statement of Applicability. |
| A.6.2.4 Verification and validation |
| Extend Your GOVERN 4.3 work supports control A.6.2.4. Implement it as a control and record it in your Statement of Applicability. |
| A.6.2.5 Deployment planned and checked |
| Extend Your MEASURE 2.5 work supports control A.6.2.5. Implement it as a control and record it in your Statement of Applicability. |
| A.6.2.6 Operation and monitoring |
| Extend Your GOVERN 1.7 work supports control A.6.2.6. Implement it as a control and record it in your Statement of Applicability. |
| A.6.2.7 Technical documentation for those who need it |
| Extend Your GOVERN 4.3 work supports control A.6.2.7. Implement it as a control and record it in your Statement of Applicability. |
| A.6.2.8 Event logs while AI systems are in use |
| Extend Your MEASURE 2.4 work supports control A.6.2.8. Implement it as a control and record it in your Statement of Applicability. |
| Data | ||
| A.7.2 Data management for development and enhancement |
| Extend Your MAP 2.3 work supports control A.7.2. Implement it as a control and record it in your Statement of Applicability. |
| A.7.3 How data is acquired and selected |
| Extend Your MAP 2.3 work supports control A.7.3. Implement it as a control and record it in your Statement of Applicability. |
| A.7.4 Data quality requirements |
| Extend Your MAP 2.3 work supports control A.7.4. Implement it as a control and record it in your Statement of Applicability. |
| A.7.5 Data provenance recorded |
| Extend Your MAP 2.3 work supports control A.7.5. Implement it as a control and record it in your Statement of Applicability. |
| A.7.6 Data preparation criteria |
| Extend Your MAP 2.3 work supports control A.7.6. Implement it as a control and record it in your Statement of Applicability. |
| Transparency | ||
| A.8.2 Information for the system’s users |
| Extend Your GOVERN 4.3 work supports control A.8.2. Implement it as a control and record it in your Statement of Applicability. |
| A.8.3 A channel to report adverse impacts |
| Extend Your GOVERN 4.3 work supports control A.8.3. Implement it as a control and record it in your Statement of Applicability. |
| A.8.4 A plan to tell users about incidents |
| Extend Your GOVERN 4.3 work supports control A.8.4. Implement it as a control and record it in your Statement of Applicability. |
| A.8.5 Information owed to interested parties |
| Extend Your GOVERN 4.2 work supports control A.8.5. Implement it as a control and record it in your Statement of Applicability. |
| Responsible use | ||
| A.9.2 Processes for responsible use |
| Extend Your GOVERN 4.1 work supports control A.9.2. Implement it as a control and record it in your Statement of Applicability. |
| A.9.3 Objectives for responsible use |
| Extend Your GOVERN 1.2 work supports control A.9.3. Implement it as a control and record it in your Statement of Applicability. |
| A.9.4 Use kept to the intended purpose |
| Extend Your MAP 1.4 work supports control A.9.4. Implement it as a control and record it in your Statement of Applicability. |
| Third parties | ||
| A.10.2 Responsibilities shared across the AI supply chain |
| Extend Your GOVERN 6.1 work supports control A.10.2. Implement it as a control and record it in your Statement of Applicability. |
| A.10.3 Suppliers of AI services, products and data |
| Extend Your GOVERN 1.2 work supports control A.10.3. Implement it as a control and record it in your Statement of Applicability. |
| A.10.4 Customers’ needs and expectations met |
| Extend Your GOVERN 5.1 work supports control A.10.4. Implement it as a control and record it in your Statement of Applicability. |
What to do with each document
The documented information ISO/IEC 42001 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 NIST AI RMF to ISO/IEC 42001
-
Scope and roles
- Set the AIMS scope: which AI systems, and your role for each
- Name top management’s responsibilities
-
Policy and objectives
- Write the AI policy from your AI RMF governance practices
- Set measurable AI objectives
-
Risk and impact
- Turn your MAP and MEASURE work into a documented AI risk assessment and treatment process
- Formalise AI system impact assessment (ISO/IEC 42005 gives guidance)
-
Controls
- Go through Annex A and write the Statement of Applicability
- Use the crosswalk to find the AI RMF work behind each control
-
Run and check
- Operate the AIMS and keep its records
- Internal audit and management review
-
Certification
- Choose an accredited certification body for ISO/IEC 42001
- Plan the stage 1 and stage 2 audits
Certification and audits
- ISO/IEC 42001 can be certified by an accredited certification body: a stage 1 and a stage 2 audit, then surveillance audits.
- Your AI RMF profile helps auditors see how risk is managed, but it isn’t evidence on its own: they will look for the AIMS records.
Common pitfalls
- Expecting the AI RMF profile to become the AIMS. The standard needs a managed system with documented information, audits and reviews.
- Missing what the crosswalk leaves out: interested parties (4.2), planning changes (6.3) and operational planning (8.1).
- Leaving the Statement of Applicability to the end. It drives the Annex A work and the audit.
NIST AI RMF and ISO/IEC 42001 at a glance
| Fact | NIST AI RMF | ISO/IEC 42001 |
|---|---|---|
| What it is | Voluntary framework | Certifiable standard |
| How it applies | Voluntary (adopted by choice) | Voluntary, often required by customers |
| How you show it | Voluntary: no certification of its own | Certification by an accredited certification body |
| Where | United States, International | International |
| Covers | AI governance, Risk management | AI governance, Risk management, Audit & assurance |
| Issued or enforced by | National Institute of Standards and Technology (NIST), US Department of Commerce | ISO and IEC (ISO/IEC JTC 1/SC 42 Artificial intelligence) |
| Current edition or status | AI RMF 1.0 (NIST AI 100-1, January 2023), with the Generative AI Profile (NIST AI 600-1, July 2024) and the online AI RMF Playbook. | ISO/IEC 42001:2023, first edition (December 2023). Supporting standards include ISO/IEC 42005 (impact assessment) and ISO/IEC 42006 (certification bodies). |
Next steps on MajorCyber™
Sources
- NIST AI RMF to ISO/IEC FDIS 42001 AI Management System Crosswalk — NIST AI Resource Center
- Crosswalk documents — NIST AI Resource Center
- Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1 — NIST
- ISO/IEC 42001:2023, AI management system — ISO
Open questions
- NIST’s crosswalk was made against the final draft of ISO/IEC 42001 and cites the Annex B guidance numbers. The published standard kept that numbering, and every reference here is checked against it.
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.