AICM AtlasCSA AI Controls Matrix
BCR · Business Continuity Management and Operational Resilience
BCR-01Cloud & AI Related

Business Continuity Management Policy and Procedures

Specification

Establish, document, approve, communicate, apply, evaluate and maintain business continuity management and operational resilience policies and procedures. Review and update the policies and procedures at least annually, or when significant changes occur that could impact risk exposure.

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 storage, Resource provisioning, Team and expertise

Development

Not applicable

Evaluation

Not applicable

Deployment

AI applications, Orchestration

Delivery

Operations, Continuous monitoring, Maintenance

Retirement

Archiving, Data deletion, Model disposal

Ownership / SSRM

PI

Shared across the supply chain

Shared control ownership refers to responsibilities and activities related to LLM security that are distributed across multiple stakeholders within the AI supply chain, including the Cloud Service Provider (CSP), Model Provider (MP), Orchestrated Service Provider (OSP), Application Provider (AP), and Customer (AIC). These controls require coordinated actions, communication, and governance across all involved parties to ensure their effectiveness.

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

[ AI providers MP, OSP, and AP] and AIC unless exempted.
1. Preparedness Planning: Establish comprehensive strategies to maintain essential functions during disruptions, with documented procedures for system restoration and function resumption with defined RTO and RPO.

2. Redundancy Implementation: Deploy backup systems, duplicated resources, and alternative processing pathways to prevent single-point vulnerabilities across the entire solution stack.

3. Collaborative Incident Response: Maintain clear communication channels and coordinated protocols for rapid joint action when unexpected challenges arise.

4. Regular Simulation Exercises: Conduct scheduled scenario-based readiness assessments to validate recovery procedures and identify improvement opportunities.

5. Continuous Enhancement: Implement feedback mechanisms to evolve resilience capabilities based on lessons from actual events and preparation activities.

6. Transparent Documentation: Maintain accessible records of architecture diagrams, dependency maps, and recovery instructions for all system components.

7. Shared Responsibility Matrix: Clearly define each party's accountability for maintaining operational stability throughout normal conditions and during exceptional circumstances.

8. Compliance Verification: Ensure all safeguards meet or exceed applicable industry standards and regulatory requirements for critical system protection.

9. Approval Process: Conduct initial technical assessment by subject matter experts(SMEs) for accuracy and completeness which should be then reviewed by cross-functional stakeholders for interdependency validation. Present final documentation to all stakeholders for formal endorsement

10. Communication: Distribute approved policies through multiple channels and briefing sessions with stakeholders and personnel with key roles. Create a shared terminology reference to ensure consistent understanding of terms and method for communication protocols for coordinated response.

11. Update: Schedule comprehensive review at minimum annually, while performing immediate assessment when there is architectural, system or dependency change. Updates should be associated with trigger events or review cycles and also need to be done when regulatory or compliance requirements dictate.

12. Change Management: Change control processes ensure that changes to the environment are carefully planned, reviewed, approved by Change Control Board, and implemented in a controlled manner. This helps prevent unauthorized or unintended changes that could disrupt service delivery or compromise security. Documentation of rollback procedures and post change validation.

Auditing guidelines

1. Establishment and Documentation: Verify that formal Business Continuity Management (BCM) and operational resilience policies and procedures explicitly address continuity requirements related to AI, application services, and delivered products. For Model Providers (MP) specifically, confirm that the policy covers upkeep, supportability, versioning, and retraining of AI models, particularly where their availability or behavior directly impacts downstream systems or customers. Ensure policies document detailed roles, responsibilities, objectives, and scope, including dependencies on model behavior, compute environments, and model-serving infrastructure. Confirm the identification of upstream and downstream interfaces and dependencies, such as AI pipelines, orchestration layers, or inference endpoints, and how continuity risks at each point are managed.

2. Approval and Communication: Confirm that policies and procedures are approved by senior management or governing bodies and that evidence of formal endorsement (e.g., signatures, meeting minutes) is maintained. Verify the presence of a robust document control process for managing revisions, release control, and versioning to ensure the latest policy is always accessible. Ensure effective communication of continuity policies to internal and external stakeholders, including third-party vendors, with supporting materials such as training logs, stakeholder memos, and BCM awareness sessions.

3. Application and Implementation: Evaluate whether the policy is implemented in practice, including operational execution of 
responsibilities. For MPs, verify that continuity planning includes model retraining schedules, rollback strategies, failure isolation plans, and incident handling for model outages or data drift. Confirm clear role definitions for continuity, and validate that they are being actively fulfilled in AI service teams and operational support.

4. Evaluation and Maintenance: Verify that the BCM policy is reviewed at least annually or upon significant changes (e.g., new model deployments, cloud migrations, architectural changes). Confirm that triggers for reassessment, such as introduction of high-dependency AI models, changes in inference service SLAs, or new customer impact scenarios, are documented and linked to update logs. Ensure KPIs are tracked to measure effectiveness of continuity planning, including model uptime, failure recovery times, and retraining impact windows. Verify that lessons learned from incidents, tests, and audits are used to refine the BCM policy. Confirm that policies align with external standards and regulatory expectations (e.g., ISO 22301, industry resilience benchmarks), and are validated through internal or third-party reviews.

From CCM:
1. Examine policy and procedures for adequacy, approval, communication, and effectiveness as applicable to business continuity and resilience.
2. Examine policy and procedures for evidence of review at least annually.

Standards mappings

ISO 42001No Gap
42001: A.2.2
42001: A.2.3
42001: A.2.4
27001: A.5.30
Addendum

N/A

EU AI ActPartial Gap
Article 15 (4),
Article 17,
Annex VII,
Recital 51,
Recital 15
Addendum

Explicitly mandate BCM policies and procedures, Require annual or event-driven reviews, Include testing and validation of continuity plans, Align continuity expectations with risk levels of AI systems, Ensure cross-actor responsibility in distributed AI deployments.

NIST AI 600-1Full Gap
No Mapping
Addendum

The whole BCR-01 control. Establish and maintain formal business continuity and operational resilience policies and procedures, with mandatory annual reviews or updates triggered by significant changes to clearly cover the desired control.

BSI AIC4No Gap
C4 PC-01
C5 BCM-02
Addendum

N/A

AI-CAIQ questions (2)

BCR-01.1

Are business continuity management and operational resilience policies and procedures established, documented, approved, communicated, applied, evaluated, and maintained?

BCR-01.2

Are policies and procedures reviewed and updated at least annually, or when significant changes occur that could impact risk exposure?