AICM AtlasCSA AI Controls Matrix
STA · Supply Chain Management, Transparency, and Accountability
STA-06Cloud & AI Related

SSRM Documentation Review

Specification

Review and validate SSRM 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

Data storage, Resource provisioning

Development

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

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. Regularly review and validate SSRM documentation to ensure it accurately reflects current system design, business objectives, threat landscape, and mitigation practices.

2. Conduct a comprehensive review of SSRM-related documents, including risk assessments, mitigation plans, and supplier evaluations.

3. Ensure that all relevant stakeholders have access to the most current and accurate SSRM documentation.

4. Document changes made during the review process and communicate updates to all relevant parties.

Auditing guidelines

1. Confirm the Cloud Service Provider (CSP) has a process to regularly review its own SSRM documentation and that of key suppliers (e.g., hardware vendors, colocation providers), ensuring shared responsibilities are clearly defined and current by updating its matrix to reflect infrastructure-layer responsibilities such as physical security, virtualization, and network segmentation.

2. Verify these reviews are conducted at least annually or when major service changes occur (e.g., new data center deployments, platform upgrades), ensuring the SSRM reflects changes in control ownership, data handling, and operational responsibilities.

Standards mappings

ISO 42001No Gap
42001: A.2.3 Alignment with other organizational policies
42001: A.10.2 Allocating Responsibilities
27001: 9.1 Monitoring
measurement
analysis and evaluation
27001: 9.3 Management review
27001: A.5.20 Addressing information security within supplier agreements
27001: A.5.23  Information security for use of cloud services
27002: A.5.20 Addressing information security within supplier agreements
27002: 5.23 Information security for use of cloud services
Addendum

N/A

EU AI ActFull Gap
Article 15
Article 17
Article 28
Annex IV (2) (f)
Annex VII (5.3)
Addendum

Mandate a dedicated SSRM documentation structure, a formal review or validation cycle, and specific review responsibilities across different actors (e.g., provider vs. deployer).

NIST AI 600-1Full Gap
No Mapping
Addendum

NIST AI 600-1 is missing SSRM documentation review and validation.

BSI AIC4No Gap
C4 PC-01
C5 SSO-04
C5 OIS-03
C5 OIS-04
Addendum

N/A

AI-CAIQ questions (1)

STA-06.1

Are the SSRM documentation reviewed and validated?