AICM AtlasCSA AI Controls Matrix
LOG · Logging and Monitoring
LOG-07Cloud & AI Related

Logging Scope

Specification

Establish, document and implement which information meta/data system events should be logged. Review and update the scope at least annually or whenever there is a change in the threat environment.

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, Resource provisioning

Development

Design, Training, Guardrails

Evaluation

Evaluation, Validation/Red Teaming, Re-evaluation

Deployment

Orchestration, AI Services supply chain, AI applications

Delivery

Operations, Maintenance, Continuous monitoring, Continuous improvement

Retirement

Data deletion

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

Shared Model Provider-Orchestrated Service Provider (Shared MP-OSP)

The MP and OSP 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

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

[All Actors]
1. Document a definitive list of events to log such as authentication/authorization, configuration changes, data-access, errors, admin actions, security alerts, model-lifecycle events, and third-party API calls.

2. Include essential metadata (timestamp, user/service identity, source IP, resource, action, result code, request ID) to enable correlation, investigation and audit.

3. Align the logging scope with business, regulatory and threat-detection needs; avoid collecting sensitive data unless absolutely necessary, and apply masking or tokenization when it is.

3. Maintain consistent log formats and schemas so that analytics tools, SIEM and forensic workflows can parse events across all environments.

4. Review and update the documented scope on a regular basis or whenever architecture, regulation or threat intelligence changes, and version-control the artefact.

Auditing guidelines

1. Inquiring with Control Owners

1.1 Conduct interviews with personnel responsible for establishing, documenting, and implementing logging scope for cloud infrastructure events and compute resource metadata to understand their process for defining which AI processing and customer workload events should be logged and their procedures for annual reviews. Verify their understanding of infrastructure security threat environment changes that trigger scope updates and their implementation of documented logging requirements across compute clusters, storage systems, and customer tenant environments.

2. Inspecting Records and Documents

2.1 Confirm documentation specifies which cloud infrastructure events must be logged (e.g., compute resource allocation, customer workload execution, storage access, network traffic, hypervisor activities).

2.2 Validate inclusion of both success and failure events in the cloud infrastructure logging scope, including successful resource provisioning and failed authentication attempts.

2.3 Ensure regular reviews of cloud infrastructure logging scope to capture evolving infrastructure security threats such as hypervisor attacks, side-channel exploits, and customer isolation breaches.

2.4 Check scope alignment with customer SLA requirements, regulatory compliance standards, and cloud service contractual obligations.

2.5 Assess procedures for adjusting logging scope when deploying new infrastructure services, AI accelerators, or customer environments.

2.6 Confirm stakeholder approval for the defined cloud infrastructure logging scope, including input from cloud operations teams, security architects, and compliance officers.

2.7 Verify logs reflect real-world cloud infrastructure events as specified in scope documents, including resource utilization, customer activities, and system operations.

2.8 Examine evidence of annual cloud infrastructure logging scope reviews and documentation of any scope updates driven by new infrastructure threats or regulatory changes.

2.9 Review procedures for monitoring and responding to infrastructure threat environment changes that may require logging scope adjustments for emerging attack vectors.

2.10 Validate that implementation of cloud infrastructure logging scope requirements is consistently applied across all compute resources, storage systems, network infrastructure, and customer tenant isolation mechanisms.

2.11 Confirm that the scope includes all infrastructure-level logs (compute, storage, network).

2.12 Validate services automatically log user actions, configuration changes, and API calls.

2.13 Assess whether default logging scope can be customized per tenant.

2.14 Ensure regular scope reviews as services or customer requirements evolve.

2.15 Verify logging of control plane and data plane events.

2.16 Review service documentation to ensure it defines and enforces consistent logging scope.

Standards mappings

ISO 42001Partial Gap
ISO 42001 A.6.2.8
Addendum

The ISO 42001 does not cover the LOG-07 topic of documenting which systems are to be logged and does not cover reviewing the list of logged items annually.

EU AI ActPartial Gap
Article 12
Addendum

Contrarily to the AICM control that provides an increased level of detail, the EU AI Act establishes more general requirements that may be interpreted as encompassing the aspects tackled in the control.

NIST AI 600-1Partial Gap
GV-1.5-001
MG-4.2-001
Addendum

There doesn't seem to be NIST AI 600-1 requirements that provide guidance on defining "system events" for monitoring or logging. There are a number of requirements, however, that provide guidance on monitoring other important events in the GAI system. As when monitoring is occurring, recording of that information in system logs is "usually" part of the configuration.

BSI AIC4No Gap
C4 PC-02
C5 OPS-10
C5 OPS-11
Addendum

N/A

AI-CAIQ questions (2)

LOG-07.1

Are information metadata system events that should be logged, established, documented, and implemented?

LOG-07.2

Is the scope reviewed and updated at least annually, or whenever there is a change in the threat environment?