STA · Supply Chain Management, Transparency, and Accountability

STA-10Cloud & AI Related

Primary Service and Contractual Agreement

Specification

Service agreements must incorporate at least the following mutually-agreed upon provisions and/or terms: • Scope, characteristics and location of business relationship and services offered • Information security requirements (including SSRM) • Change management process • Logging and monitoring capability • Incident management and communication procedures • Right to audit and third party assessment • Service termination • Interoperability and portability requirements • Data privacy

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

Development

Supply Chain

Evaluation

Validation/Red Teaming

Deployment

AI Services supply chain

Delivery

Operations, Continuous monitoring, Continuous improvement

Retirement

Data deletion

Ownership / SSRM

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 Orchestrated Service Provider-Application Provider (Shared OSP-AP)

The OSP and AP 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. Develop standardized contract templates that include all required STA-10 provisions as baseline requirements for all supply chain agreements. Incorporate all required provisions into service agreements including scope definition, service characteristics, geographic locations, and business relationship terms for all supply chain partnerships.

2. Include comprehensive information security requirements in all agreements, specifically referencing SSRM compliance obligations, security standards, and control implementation requirements. 

3. Maintain a repository of negotiated contract clauses for each STA-10 requirement to ensure consistency and leverage best practices across all agreements. Establish logging and monitoring requirements in agreements specifying data collection obligations, retention periods, access rights, and reporting frequencies.

4. Implement a process to update standard contractual terms when SSRM requirements, security standards, or regulatory obligations change. Define change management processes in contractual terms including notification procedures, approval workflows, impact assessments, and rollback provisions for service modifications.

5. Define approval workflows that require security and legal stakeholders to confirm STA-10 compliance before contracts are executed. 

6. Define service termination procedures including data return/destruction, transition assistance, and post-termination obligations.

Auditing guidelines

1. Verify that the CSP’s third-party contracts include key provisions covering service scope, SSRM-aligned security, change management, monitoring, incident response, audit rights, termination, interoperability, and data privacy.

2. Assess whether the cloud service provider (CSP) regularly reviews and updates third-party agreements to reflect evolving security standards, regulatory requirements, and operational changes, and ensures that third parties remain compliant through audits or performance evaluations.

Standards mappings

ISO 42001Partial Gap

42001: A.2.3 Alignment with other organizational policies
42001: A.10.4 Customers
42001: A.6.1 Risk assessment for AI systems
42001: A.6.3.2 Planning of AI-specific controls
42001: A.8.2.2 Operational planning and control
42001: A.8.3.1 Data governance
27001: A.5.19 Information security in supplier relationships
27001: A.5.20 Addressing information security within supplier agreements
27001: A.5.23 Information security for use of cloud services
27001: A.8.30 Outsourced Development
27002: 5.19 Information security in supplier relationships
27002: 5.20 Addressing information security within supplier agreements
27002: 5.23 Information security for use of cloud services

Addendum

Supplier/service agreement controls Contractual clause requirements Audit and accountability expectations Portability and data ownership safeguards (Currently these are included in 27001 and 27002)

EU AI ActPartial Gap

Article 9
Article 13 & Annex IV
Article 15
Article 17
Article 25 (4)
Article 53 (1) (e)

Addendum

Draft appropriate service agreement clauses, extend internal governance policies to their vendors, and ensure contractual alignment with EU AI Act–driven operational responsibilities.

NIST AI 600-1No Gap

GV-6.1-004

Addendum

N/A

BSI AIC4No Gap

C4 PC-01
C4 PC-02
C5 SSO-01
C5 SSO-03
C5 SSO-05

Addendum

N/A

AI-CAIQ questions (1)

STA-10.1

Are service agreements required to include at least the following mutually agreed upon provisions and/or terms? • Scope, characteristics and location of business relationship and services offered • Information security requirements (including SSRM) • Change management process • Logging and monitoring capability • Incident management and communication procedures • Right to audit and third party assessment • Service termination • Interoperability and portability requirements • Data privacy