Artificial Intelligence is no longer confined to specialized labs or niche technology providers; it is now embedded across industries, powering collaboration tools, customer service platforms, and mission-critical workflows. With this rapid adoption comes a pressing need for governance and accountability.
ISO 42001 is not just another AI standard.
It is a comprehensive framework that applies to any organization that provides, builds, or uses AI systems, whether developing foundation models, integrating them into products, or simply enabling tools like Zoom AI or Copilot for internal teams.
The central scoping question is straightforward: Do you provide, develop, or use AI? If the answer is yes, ISO 42001 applies. Yet many CISOs, CIOs, and compliance leaders mistakenly assume it is relevant only to “AI companies.” In reality, AI risk is emerging across most organizations through three distinct roles:
- User: internally using AI tools such as Zoom AI for summaries or Copilot in email.
- Provider: embedding AI into products or workflows, e.g., using Bedrock or Azure OpenAI in SaaS platforms.
- Developer: constructing models or core systems, such as foundation model providers.
Determining which of these roles your organization occupies is the starting point for correctly scoping ISO 42001.
Scenario 1: Just Using AI Tools Still Brings You into Scope
Organizations acting as AI Users or Acquirers rely on embedded tools such as Zoom AI, Asana AI, Jira AI, or Microsoft Copilot. Even without building models in-house, these tools process sensitive business data; customer names, project details, internal conversations, introducing AI risk into the environment.
ISO 42001 should therefore be implemented as a priority. The AI management system must treat these tools as critical third-party suppliers, similar to cloud or security vendors under ISO 27001.
Relevant clauses span 4 to 10, with Annex A controls emphasizing governance, supplier oversight, training, and data handling:
- A.2 Policies: rules for acceptable use of third-party AI tools, specifying when customer or confidential data may be shared.
- A.3 Internal Organization: assigning accountable roles for configuring, monitoring, and reviewing AI-integrated services.
- A.4 Resources for AI: equipping employees with knowledge of AI limitations, bias, and hallucinations.
- A.7 Data Management: enforcing privacy, quality, and provenance standards for data submitted to external AI tools.
- A.10 Third Party Relationships: treating AI vendors as indispensable suppliers with formal evaluations and continuous supervision.
This scenario alone demonstrates why so-called “non-AI organizations” must engage with ISO 42001.
Scenario 2: Building on Top of Foundation Models
Organizations acting as AI Developers or Providers downstream create tailored solutions over existing LLMs such as Bedrock, Lambda, or Azure OpenAI. They control the entire lifecycle of the new layer, use case definition, prompt creation, RAG integration, and application security.
To regulators and users, accountability lies with the organization delivering the AI behavior, not the base model supplier. ISO 42001 is therefore fully applicable—all clauses and Annex A controls must be implemented. Once you control prompts, business logic, data sources, and outputs, you are no longer just a user; you are providing an AI system that directly impacts customers and business outcomes.
Scenario 3: Developing Foundation Models
Organizations building foundation models themselves assume the highest level of responsibility. This includes model design, training data, testing, and release. Regulators and customers hold developers accountable for model behavior, even when embedded or reused by others.
ISO 42001 certification at this stage is not only best practice but also a mechanism for managing liability and earning customer trust. All clauses and Annex A controls apply, requiring comprehensive impact evaluations, human supervision, bias detection, incident response planning, and transparent communication to customers about AI capabilities and limitations.
Key Takeaway
These scenarios prove that ISO 42001 is a horizontal AI governance standard, not a narrow framework for specialized model labs. Whether your company:
- Enables embedded AI in collaboration or productivity tools,
- Builds custom AI workflows on top of commercial LLMs, or
- Offers AI features directly to customers,
It is already operating in at least one of the “provide, develop, or use” roles central to the standard.
For leaders in security, risk, and product, the conclusion is clear: ISO 42001 is becoming the benchmark for demonstrating responsible AI practices. Begin by aligning your organization with these scenarios, assessing your current role, anticipating where you will be in the next 12–18 months, and designing your AI governance strategy accordingly.
Bridging ISO 42001 from Theory to Practice
Understanding where ISO 42001 applies is only the first step. The real challenge for most organizations lies in operationalizing AI governance; translating roles, clauses, and Annex A controls into day-to-day processes that actually work across security, product, legal, and engineering teams. Many enterprises struggle with scoping AI usage accurately, assigning ownership, integrating third-party AI tools into existing governance models, and maintaining continuous oversight as AI systems evolve. This is where a practical, security-first approach becomes essential.
Why Choose Accorian
Navigating ISO 42001 requires more than compliance; it demands expertise in AI risk, governance, and security. Accorian brings deep experience in cybersecurity, regulatory alignment, and enterprise risk management to help organizations operationalize ISO 42001 effectively. From scoping your AI role to implementing Annex A controls, Accorian ensures your governance framework is robust, practical, and future-ready.
By partnering with Accorian, you gain not only a trusted advisor but also a strategic ally in building resilience, safeguarding sensitive data, and demonstrating responsible AI practices to regulators, customers, and stakeholders.
