AICM AtlasCSA AI Controls Matrix
MDS · Model Security
MDS-04AI-Specific

Model Documentation Requirements

Specification

Establish and implement baseline requirements for Model documentation.

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

Team and expertise

Development

Design, Supply Chain

Evaluation

Validation/Red Teaming, Re-evaluation

Deployment

AI Services supply chain, AI applications

Delivery

Operations, Continuous improvement

Retirement

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

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

Not Applicable

Auditing guidelines

1. Verify that the CSP provides tools and capabilities to support customer's model documentation requirements. 

2. Assess the CSP's documentation for how to securely manage and store model documentation. 

3. Confirm that service agreements outline clear responsibilities for model documentation security.

Standards mappings

ISO 42001No Gap
42001 A.6.2.7 - AI system technical documentation
42001 A.6.2.2 - AI system requirements and specification
42001 A.6.2.6 - AI system operation and monitoring
Addendum

N/A

EU AI ActNo Gap
Article 13 (2)
Article 13 (3)
Addendum

N/A

NIST AI 600-1No Gap
MS-2.9-002
Addendum

N/A

BSI AIC4No Gap
C4 BC-01
C4 BC-02
C4 BC-03
C4 BC-04
C4 BC-05
C4 BC-06
C4 PF-05
C4 PC-02
Addendum

N/A

AI-CAIQ questions (1)

MDS-04.1

Are baseline requirements for Model documentation established and implemented?