Computer generated image of outstretched robot arms
News

Responsible AI Implementation Checklist (with ISO/IEC 42001 Alignment)

Jul 11, 2025 · 2 min read

This quick reference guide translates ISO/IEC 42001’s AI management system principles—mapped to familiar SOC 2 Trust Services Criteria—into a focused checklist you can deploy when introducing AI within your own firm or guiding clients through responsible adoption.

Use it to trigger the right questions, anchor risk discussions, and demonstrate leadership in AI governance while advancing your professional growth and the value you deliver.


Governance & Leadership

  • Define an AI governance structure with executive accountability

  • Establish an AI policy framework aligned with ISO/IEC 42001

  • Maintain a formal AI risk management process

  • Engage stakeholders to define acceptable AI use and boundaries

  • Appoint an AI oversight role or team (e.g., AIMS owner)


AI Lifecycle Management

  • Maintain documented procedures for model development, deployment, and retirement

  • Ensure explainability and traceability of models and outcomes

  • Track model performance, accuracy, and limitations over time

  • Implement change management for models and associated datasets

  • Apply lifecycle controls consistently across internal and third-party AI


Security, Controls & Trust Criteria

  • Treat AI systems as protected assets—apply access, identity, and version control

  • Integrate AI controls with broader security operations (e.g., monitoring, incident response)

  • Regularly test for adversarial threats and abuse scenarios

  • Align security and privacy practices with SOC 2 criteria (confidentiality, integrity, etc.)

  • Apply ISO/IEC 42001 Annex A controls where applicable to mitigate specific risks


Data Integrity & Ethics

  • Use high-quality, unbiased, and traceable training data

  • Implement data quality controls and validation checkpoints

  • Evaluate for fairness, bias, and disparate impact

  • Apply privacy-by-design principles to all AI data workflows

  • Maintain transparency on how data is used and retained


Documentation & Audit Readiness

  • Keep comprehensive records of model logic, inputs, outputs, and decisions

  • Log AI-related incidents, changes, and risk treatments

  • Provide clear documentation for internal audits and external assurance reviews

  • Map AI controls and processes to ISO/IEC 42001 and SOC 2 frameworks

  • Conduct regular reviews of AIMS effectiveness and make updates as needed


Transparency & Accountability

  • Disclose AI usage to customers, clients, or affected users when appropriate

  • Provide channels for questions, disputes, or opt-outs related to AI decisions

  • Train staff on responsible AI use, risks, and escalation procedures

  • Embed ethical considerations into procurement of AI tools and vendors

  • Perform periodic assessments of AI impact on users and stakeholders


About

The Technology Strategic Advisory Group exists to promote the professional development and career growth of CITP credential holders and other stakeholders by creating and curating resources that address emerging needs in technology and business. Committed to fostering continuous learning, innovation, and adaptability, the group provides insights and support to help professionals navigate challenges, expand their expertise, and lead with confidence. Through collaboration and strategic initiatives, the group ensures that the CITP community and related professionals remain connected, informed, and prepared for the future.

Raymond Cheng, CPA, CITP, CISSP, CISA, CCSK, CIPP/E

Raymond Cheng is the CEO and Managing Partner of Decrypt Compliance, a Silicon Valley-based CPA firm he founded in 2023. Raymond and his team specialize in technology-related internal controls audits (cybersecurity, privacy, AI) for high-growth companies, primarily of SOC 2, ISO 27001, and other industry-leading frameworks. With over a decade of experience in the technology sector, Raymond has conducted 50+ cybersecurity audits at EY and implemented technology risk & compliance programs at Fortune 500 companies including Salesforce and Tencent. He is a thought leader and frequent speaker on topics such as cybersecurity audits, multi-framework compliance, and the intersection of accounting and technology. Raymond serves as a CITP Champion for California and is also a board member of the San Francisco Bay Area Rotary Club, where he applies his professional skills to promote global humanitarian efforts.

What did you think of this?

Every bit of feedback you provide will help us improve your experience

What did you think of this?

Every bit of feedback you provide will help us improve your experience

Mentioned in this article

Topics

Subtopics

Manage preferences

Related content

}