AICM AtlasCSA AI Controls Matrix
A&A · Audit & Assurance
A&A-04Cloud & AI Related

Requirements Compliance

Specification

Verify compliance with all relevant standards, regulations, legal/contractual, and statutory requirements applicable to the audit.

Threat coverage

Model manipulation
Data poisoning
Sensitive data disclosure
Model theft
Model/Service Failure
Insecure supply chain
Insecure apps/plugins
Denial of Service
Loss of governance

Architectural relevance

Physical infrastructure
Network
Compute
Storage
Application
Data

Lifecycle

Preparation

Data collection, Data curation, Data storage

Development

Design, Training, Guardrails

Evaluation

Evaluation, Validation/Red Teaming, Re-evaluation

Deployment

AI Services supply chain, AI applications

Delivery

Operations, Maintenance, Continuous improvement

Retirement

Archiving, Data deletion, Model disposal

Ownership / SSRM

PI

Shared Cloud Service Provider-Model Provider (Shared CSP-MP)

The CSP and MP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.

Model

Owned by the Model Provider (MP)

The model provider (MP) designs, develops, and implements the control as part of their services or products to mitigate security, privacy, or compliance risks associated with the Large Language Model (LLM). Model Providers are entities that develop, train, and distribute foundational and fine-tuned AI models for various applications. They create the underlying AI capabilities that other actors build upon. Model Providers are responsible for model architecture, training methodologies, performance characteristics, and documentation of capabilities and limitations. They operate at the foundation layer of the AI stack and may provide direct API access to their models. Examples: OpenAI (GPT, DALL-E, Whisper), Anthropic(Claude), Google(Gemini), Meta(Llama), as well as any customized model.

Orchestrated

Owned by the Orchestrated Service Provider (OSP)

The Orchestrated Service Provider (OSP) is responsible for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer. The OSP is responsible and accountable for the implementation of the control within its own infrastructure/environment. If the control has downstream implications on the users/customers, the OSP is responsible for enabling the customer and/or upstream partner in the implementation/configuration of the control within their risk management approach. The OSP is accountable for ensuring that its providers upstream (e.g MPs) implement the control as it relates to the service/product the develop and offered by the OSP. This refers to entities that create the technical building blocks and management tools that enable AI implementation. This can include platforms, frameworks, and tools that facilitate the integration, deployment, and management of AI models within enterprise workflows. These providers focus on model orchestration and offer services like API access, automated scaling, prompt management, workflow automation, monitoring, and governance rather than end-user functionality or raw infrastructure. They help businesses implement AI in a structured and efficient manner. Examples: AWS, Azure, GCP, OpenAI, Anthropic, LangChain (for AI workflow orchestration), Anyscale (Ray for distributed AI workloads), Databricks (MLflow), IBM Watson Orchestrate, and developer platforms like Google AI Studio.

Application

Owned by the Application Provider (AP)

The Application Provider (AP) is responsible for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer. The AP is responsible and accountable for the implementation of the control within its own infrastructure/environment. If the control has downstream implications on the users/customers, the AP is responsible for enabling the customer and/or upstream partner in the implementation/configuration of the control within their risk management approach. The AP is accountable for carrying out the due diligence on its upstream providers (e.g MPs, Orchestrated Services) to verify that they implement the control as it relates to the service/product develop and offered by the AP. These providers build and offer end-user applications that leverage generative AI models for specific tasks such as content creation, chatbots, code generation, and enterprise automation. These applications are often delivered as software-as-a-service (SaaS) solutions. These providers focus on user interfaces, application logic, domain-specific functionality, and overall user experience rather than underlying model development. Example: OpenAI (GPTs,Assistants), Zapier, CustomGPT, Microsoft Copilot (integrated into Office products), Jasper (AI-driven content generation), Notion AI (AI-enhanced productivity tools), Adobe Firefly (AI-generated media), and AI-powered customer service solutions like Amazon Rufus, as well as any organization that develops its AI-based application internally.

Implementation guidelines

Compliance with relevant standards, regulations, legal, contractual, and statutory requirements is critical for ensuring that AI systems operate within the boundaries of the law and adhere to organizational and industry-specific obligations.

[All Providers: MP, OSP, AP]
1. Compliance Identification: Identify all applicable regulations governing AI systems (GDPR, HIPAA, CCPA, ISO 27001, NIST AI RMF, EU AI Act) across relevant jurisdictions where AI components are developed, deployed, or used.

2. Governance Integration: Integrate compliance checks into AI governance frameworks to ensure consistent implementation across model development, training data management, deployment infrastructure, and monitoring systems.

3. Assessment and Verification: Conduct periodic gap analyses and compliance audits to identify discrepancies between current practices and requirements, with focus on data protection, model transparency, fairness, and security controls.

4. Monitoring and Documentation: Establish systems to track regulatory changes relevant to AI systems, maintain comprehensive audit trails, and document evidence including policies, logs, training records, and system configurations.

Auditing guidelines

1. Examine the process for determining the standards and regulations applicable to the organization's systems and environments.

2. Examine the process to determine contractual, legal, and technical requirements applicable to the organization's systems and environments.

3. Determine if the organization maintains and reviews a list of relevant standards, regulations, legal/contractual, and statutory requirements.
 
4. Determine if senior management exercises oversight of this control specification. 

5. Determine if the audit plan is informed by the list of the organization's requirements.

Standards mappings

ISO 42001No Gap
42001: 8.2.1(a) Compliance with legal and regulatory requirements
42001: 9.2.1 General
27001: 9.2.1 General
27001: A 5.31 Legal
statutory
regulatory and contractual requirements
27002: 5.31 Legal
statutory
regulatory and contractual requirements
Addendum

N/A

EU AI ActNo Gap
Article 8
Article 43
Article 53
Article 55
Addendum

N/A

NIST AI 600-1No Gap
GV-1.1-001
Addendum

N/A

BSI AIC4No Gap
COM-01
Addendum

N/A

AI-CAIQ questions (1)

A&A-04.1

Is compliance verified with all relevant standards, regulations, legal/contractual, and statutory requirements applicable to the audit?