AICM AtlasCSA AI Controls Matrix
TVM · Threat & Vulnerability Management
TVM-09Cloud & AI Related

Vulnerability Management Reporting

Specification

Define and implement a process for tracking and reporting vulnerability identification and remediation activities that includes stakeholder notification.

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

Training

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 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. Maintain a central system that tracks vulnerabilities from discovery through remediation, showing status, owner, severity and due date.

2. Implement a process for verifying the effectiveness of vulnerability remediation efforts, ensuring that identified vulnerabilities have been fully addressed.

2. After remediation, conduct tests to confirm that the vulnerability is no longer exploitable and that the system functions as intended.

3. Use automated tools and manual testing to verify that the patch or mitigation has been successfully applied.

4. Record verification activities, including test results and verification reports, to ensure accountability and transparency.

5. Communicate verification results to relevant stakeholders, including internal teams, management, and external parties if necessary.

6. Periodically review the tracking and verification process to ensure it remains aligned with evolving business goals, threat landscape and regulatory duties. Communicate verification results to relevant stakeholders, including notification of downstream or dependent actors when the vulnerability or patch is relevant to their systems.

Auditing guidelines

1. Verify that the Cloud Service Provider (CSP) has defined a process to systematically document both the vulnerabilities identified within the security perimeter and the activities implemented to remediate them. Ensure that the process is documented in detail, covering scope, objectives, roles and responsibilities.

2. Examine the above-mentioned process to verify that it includes a notification phase to relevant stakeholders.

3. Confirm that the above-mentioned process is communicated and thoroughly comprehended by relevant parties.

4. Confirm that the above-mentioned process is concretely and appropriately implemented by responsible parties.

5. Inspect whether the above-mentioned process is monitored against sets of efficacy and efficiency metrics / indicators.

6. Inspect whether the above-mentioned process is periodically reviewed and updated by responsible parties.

Standards mappings

ISO 42001Partial Gap
42001: A.6.2.6 AI system operation and monitoring
42001: A.8.4 Reporting and stakeholder notification
42001: A.6.1 / A.6.3.2 Risk and control planning
27001: 5.26 Response to information sec. inc
27001: 8.8 Management of technical vulnerabilities
27002: 8.8 Technical vulnerability management
27002: 5.7: Threat intelligence
Addendum

The organization should define and implement a process for identifying, tracking, and remediating vulnerabilities within AI systems, components, and dependencies. This process should include: Logging of vulnerabilities and their statuses, Documentation of remediation actions, Periodic reporting to relevant stakeholders, Alignment with the organization’s vulnerability and incident management procedures.

EU AI ActNo Gap
Article 72 (2) (d)
Article 73
Addendum

N/A

NIST AI 600-1Partial Gap
GV-2.1-001
GV-4.3-002
MG-2.4-003
MS-2.7-001
Addendum

NIST AI 600-1 does not specifically reference "tracking and reporting vulnerabilities."

BSI AIC4No Gap
C4 SR-02
C4 SR-03
C5 COM-04
Addendum

N/A

AI-CAIQ questions (1)

TVM-09.1

Are processes defined and implemented for tracking and reporting vulnerability identification and remediation activities that include stakeholder notification?