AICM AtlasCSA AI Controls Matrix
STA · Supply Chain Management, Transparency, and Accountability
STA-03Cloud & AI Related

SSRM Supply Chain

Specification

Apply, document, implement and manage the SSRM throughout the supply chain.

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

Guardrails, Supply Chain

Evaluation

Evaluation, Validation/Red Teaming, Re-evaluation

Deployment

Orchestration, AI Services supply chain, AI applications

Delivery

Operations, Maintenance, Continuous monitoring, Continuous improvement

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

[All Actors]
1. Apply the SSRM policy to manage risks throughout the entire supply chain, from the selection of suppliers to the delivery of products and services.

2. Implement processes to regularly assess the security posture of key suppliers and partners, ensuring they meet organizational security and compliance standards.

3. Document the identification and categorization of supply chain risks based on their potential impact on business operations and security.

4. Develop and document mitigation strategies to address high-priority supply chain risks and vulnerabilities.

5. Implement monitoring mechanisms to track supply chain security performance, ensuring continuous improvement.

Auditing guidelines

1. Confirm that the CSP publishes its SSRM in customer-facing materials, contracts, and service documentation, clearly outlining shared responsibilities for infrastructure, platform services, and security boundaries.

2. Assess how the CSP implements and governs inherited responsibilities from hardware vendors, third-party service integrations, or regional data center operators, and how these are incorporated into its own operational and security frameworks.

3. Review the CSP’s responsibility matrix, ensuring it clearly defines roles and obligations across the supply chain including hardware providers, orchestration layers, model developers, application providers, and customers to support transparency, accountability, and compliance.

Standards mappings

ISO 42001No Gap
42001: A.2.3 Alignment with other organizational policies
42001: A.10.2 Allocating Responsibilities
27001: A.5.2 Information security roles and responsibilities
27001: A.5.19 Information security in supplier relationships
27001: A.5.20 Addressing information security within supplier agreements
27001: A.5.22 Monitoring
review and change management of supplier services
27001: A 5.23 Information security for use of cloud services
27002: 5.2 Information security roles and responsibilities
27002: 5.19 Information security in supplier relationships
27002: 5.20 Addressing information security within supplier agreements
27002: 5.22 Monitoring
review and change management of supplier services
27002: 5.23 Information security for use of cloud services
Addendum

N/A

EU AI ActPartial Gap
Article 17
Article 25
Addendum

Assess third-party risk, implement SSRM controls end-to-end across supply chains, maintain shared documentation and governance of SSRM practices, and include oversight or auditability of how SSRM responsibilities are fulfilled throughout the chain.

NIST AI 600-1No Gap
GV-6.1-004
GV-3.1-001
MP-1.1-001
GV-5.1-001
Addendum

N/A

BSI AIC4No Gap
C4 BC-01
C5 BC-01
Addendum

N/A

AI-CAIQ questions (1)

STA-03.1

Is the SSRM applied, documented, implemented and managed throughout the supply chain?