AI Competency Training
Specification
Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures defining the AI training program for all relevant personnel of the organization based on their roles and provide regular training updates.
Threat coverage
Architectural relevance
Lifecycle
Team and expertise
Supply Chain
Not applicable
AI Services supply chain
Not applicable
Not applicable
Ownership / SSRM
PI
Owned by the Customer (AIC)
The Customer (AIC) is 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 services or products they consume.
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
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.
Application
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.
Implementation guidelines
Auditing guidelines
1. Verify the cloud service provider has an approved AI training policy aligned with its infrastructure, platform services, and AI offerings (e.g., covering responsible use of hosted models and compute resources). 2. Verify that the training program defines role-specific paths (e.g., cloud engineers on secure AI deployment, support teams on identifying misuse, sales teams on responsible customer onboarding). 3. Ensure training is accessible and delivered through onboarding, internal portals, or team-based sessions across technical and customer-facing roles. 4. Review participation records to confirm staff receive training relevant to their responsibilities in managing and supporting AI services. 5. Evaluate effectiveness through assessments or feedback, and confirm updates are made following incidents, customer misuse, or audits. 6. Confirm training content is regularly updated to reflect new AI services, regulatory changes, or evolving customer use cases.
Standards mappings
42001: 5.3 Roles responsibilities and authorities 42001: 7.2 Competence 42001: 7.3 Awareness 42001: A.3.2 AI Roles and responsibilities 42001: A.4.6 Human Resource
Addendum
N/A
Recital 91 Article 4
Addendum
The EU AI Act does not mandate organizations to establish, document, or update formal training programs. It applies only to high-risk AI system personnel, not all relevant personnel. It does not include requirements to establish or maintain a formal AI training program. No documentation, communication, or evaluation of training programs is required. No cadence (e.g., regular updates) is prescribed.
GV-2.1-003 MP-1.2-001 MP-3.4-003 MP-4.1-003
Addendum
N/A
C5 HR-03
Addendum
No C4 control speaks to HRS-14 topic of AI Training for personnel.
AI-CAIQ questions (2)
Are the policies and procedures defining the AI training program for all relevant personnel of the organization established, documented, approved, communicated, applied, evaluated, and maintained?
Are regular training updates given to personnel based on their roles?