Overview of key updates
- Updated 26 requirements based on audit experience, input from technical contributors, feedback from AIUC-1 Consortium members, and external peer-review comments.
- Detailed typical evidence submitted to pass AIUC-1 with suggested locations and concrete examples, making it easier for organizations to begin a readiness assessment of AIUC-1.
- Published AIUC-1 scoping questionnaire and certification process details to ensure consistent application of AIUC-1 across accredited auditors.
Detailed change log
| Date | AIUC-1 requirement and control | Category | Change notes |
|---|---|---|---|
| Q1 2026 | All requirements | New addition | Defined and published typical evidence for all controls tagged by evidence category and typical location |
| Q1 2026 | Scoping questionnaire | New addition | Published the AIUC-1 scoping questionnaire, enabling consistent approach to scoping by accredited auditors |
| Q1 2026 | All requirements | New addition | Tagged all requirements with relevant AI agent capabilities which are used as input for the scoping questionnaire to ensure appropriate application of AIUC-1 requirements |
| Q1 2026 | All requirements | New addition | Enabled Excel export of all requirements and controls for easier readiness assessment |
| Q1 2026 | Should include and May include control activities | Clarification | Clarified application of control activities For controls labeled “Should include”: Organizations must demonstrate core controls to meet the requirement. Auditors may accept alternative implementations that achieve equivalent outcomes For controls labeled “May include”: Supplemental controls demonstrating additional safeguards. Recommended when particularly relevant to the organization’s use case |
| Q1 2026 | A001: Establish input data policy | Specification | Specified evidence requirements across policies and enforcement of policies, particularly for data retention |
| Q1 2026 | A003: Limit AI agent data collection | Revision | Removed optional control activity focused on dynamic context-based restrictions given limited technical pathways for implementation |
| Q1 2026 | A004: Protect IP & trade secrets | Specification | Specified controls with a stricter requirement of user guardrails Provided specific guidance on foundation model IP protections Added supplemental safeguards |
| Q1 2026 | A005: Prevent cross-customer data exposure | Revision | Revised controls to avoid overlap and specify the intent of the requirement Removed optional controls on adapting safeguards to industry-specific risks Removed optional controls on inference-time data isolation |
| Q1 2026 | A006: Prevent PII leakage | Specification | Increased PII protection requirements for logs Removed incident management control to avoid overlap with E001 Removed cross-tenant contaminant control to avoid overlap with A005 |
| Q1 2026 | A007: Prevent IP violations | Clarification | Clarified controls with emphasis on foundation model IP protections Added additional safeguards tagged as supplemental controls Removed third-party IP incident response control to avoid overlap with other requirements |
| Q1 2026 | B006: Limit AI agent system access | Clarification | Clarified the requirement’s focus on security aspects of system limiting Emphasized agent privilege restrictions and monitoring |
| Q1 2026 | B008: Protect model deployment environment | Specification | Included Trail of Bits’ Fickling tool as example safeguard in control B008.4 based on peer-review feedback |
| Q1 2026 | B009: Limit output over-exposure | Revision | Tagged user notification control as supplemental, recognizing it is not always in the organization’s interest to disclose output limitations Minor revisions to output fidelity limitations to align with MITRE AML-M0002 |
| Q1 2026 | C001: Define AI risk taxonomy | Revision | Simplified controls to focus on AI Risk Taxonomy documentation and reviews |
| Q1 2026 | C002: Conduct pre-deployment testing | Specification | Included explicit reference to threat modelling in controls based on peer-review feedback |
| Q1 2026 | C003: Prevent harmful outputs | Revision | Removed control on review and appeal mechanisms, which are beyond the intent of the requirement |
| Q1 2026 | C006: Prevent output vulnerabilities | Revision | Removed control on logging sanitation activities as this is beyond standard practice for organizations |
| Q1 2026 | C008: Monitor AI risk categories | Revision | Removed control on proactive detection as this is already covered by C008.2 |
| Q1 2026 | C009: Enable real-time feedback and intervention | Revision | Revised controls to cover other modalities (e.g. voice, image) Tagged review of intervention logs as a supplemental control |
| Q1 2026 | D003: Restrict unsafe tool calls | Revision | Revised controls to avoid overlap with A003 and B006 Emphasized tool call validation and monitoring specifically |
| Q1 2026 | E005: Assess cloud vs on-prem processing | Revision | Revised controls to focus on cloud vs. on-prem decisions Removed security and vendor due diligence controls covered in other requirements |
| Q1 2026 | E007: Document system change approvals | Retired | This requirement was merged into E004: Assign accountability, which already requires documenting approval with supporting evidence |
| Q1 2026 | E009: Monitor third-party access | Clarification | Clarified monitoring configuration requirement in place of purely documenting procedures |
| Q1 2026 | E010: Establish AI acceptable use policy | Clarification | Combined supplemental controls into one without changing the nature of the control activities |
| Q1 2026 | E013: Implement quality management system | Specification | Controls updated to simplify the requirement while fulfilling EU AI Act Article 17 |
| Q1 2026 | E014: Share transparency reports | Retired | This requirement was merged into E017 to avoid overlap and to recognize transparency policy sharing procedures |
| Q1 2026 | E015: Log model activity | Specification | Strengthened controls around PII protection Improved log immutability and tamper-proofing based on peer-review feedback |
| Q1 2026 | E016: Implement AI disclosure mechanisms | Revision | Revised control activities to ensure coverage of multiple modalities (e.g. voice, text, image) |
| Q1 2026 | F001: Prevent AI cyber misuse | Revision | Removed control requiring a signed attestation that cyber misuse safeguards remain active Encouraged organizations using open-source or fine-tuned third-party models to opt into the supplemental control |
| Q1 2026 | F002: Prevent catastrophic misuse | Revision | Removed control requiring a signed attestation that CBRN safeguards remain active Encouraged organizations using open-source or fine-tuned third-party models to opt into the supplemental control |
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