> ## Documentation Index > Fetch the complete documentation index at: https://standard.aiuc-1.com/llms.txt > Use this file to discover all available pages before exploring further. # AIUC-1 × CSA AICM export const InlineClock = ({city, timeZone}) => { const [time, setTime] = useState('--:--:--'); useEffect(() => { const update = () => setTime(new Intl.DateTimeFormat('en-US', { hour: '2-digit', minute: '2-digit', second: '2-digit', hour12: false, timeZone }).format(new Date())); update(); const id = setInterval(update, 1000); return () => clearInterval(id); }, [timeZone]); return
{city} {time}
; };

The Cloud Security Alliance's AI Controls Matrix provides a security controls framework specifically designed for AI/ML systems.

AIUC-1 aligns with CSA AICM. Certification against AIUC-1:

## CSA AICM crosswalks by control
| CSA AICM control | CSA AICM description | Relevant AIUC-1 requirements | Gap analysis | | -------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------- | | A\&A-01: Audit and Assurance Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain audit and assurance policies and procedures and standards. Review and update the policies and procedures at least annually or upon significant changes. |
E008: Review internal processes
| **Partial Gap.** AIUC-1 is less prescriptive, e.g., does not require audit policies | | A\&A-02: Independent Assessments | Conduct independent audit and assurance assessments according to relevant standards at least annually. |
E008: Review internal processesC010: Third-party testing for harmful outputsC012: Third-party testing for customer-defined risk
| **Full Gap.** AIUC-1 does not require external audits | | A\&A-03: Risk Based Planning
Assessment | Perform independent audit and assurance assessments in response to signifianct changes or emerging risks and according to risk-based plans and policies. |
E008: Review internal processes
| **Full Gap.** AIUC-1 does not require external audits | | A\&A-04: Requirements Compliance | Verify compliance with all relevant standards, regulations, legal/contractual, and statutory requirements applicable to the audit. |
E012: Document regulatory compliance
| No Gap | | A\&A-05: Audit Management Process | Define and implement an Audit Management process aligned with global audting standards, to support audit planning, risk analysis, security control assessment, conclusion, remediation schedules, report generation, and review of past reports and supporting evidence. |
E008: Review internal processesC001: Define AI risk taxonomyE013: Implement quality management system
| **Partial Gap.** AIUC-1 requirement is smaller in scope | | A\&A-06: Remediation | Establish, document, approve, communicate, apply, evaluate and maintain a risk-based corrective action plan to remediate audit findings, regularly review and report remediation status to relevant stakeholders. |
E008: Review internal processesC001: Define AI risk taxonomyE014: \[Retired] Share transparency reports
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | AIS-01: Application and Interface Security Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for application security. Review and update the policies and procedures at least annually or after significant system changes. |
E004: Assign accountabilityE013: Implement quality management systemE008: Review internal processesE007: \[Retired] Document system change approvals
| No Gap | | AIS-02: Application Security Baseline Requirements | Establish, document and maintain baseline requirements for securing applications. |
E008: Review internal processesB008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 does not require documented baseline security requirements for all AI applications | | AIS-03: Application Security Metrics | Define and implement technical and operational metrics in alignment with business objectives, security requirements, and compliance obligations. |
E013: Implement quality management system
| **Partial Gap.** AIUC-1 does not require specific metrics | | AIS-04: Secure Application Development Lifecycle | Define and implement a software development lifecycle (SDLC) process for application requirements analysis, planning, design, development, testing, deployment, and operation in accordance with security requirements defined by the organization. |
E004: Assign accountabilityC002: Conduct pre-deployment testing
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | AIS-05: Application Security Testing | Implement a testing strategy, including criteria for acceptance of new
information systems, upgrades and new versions, which provides
application security assurance and maintains compliance while meeting
organizational delivery goals.
Automate when applicable and possible. |
C002: Conduct pre-deployment testingE005: Document data storage securityD002: Third-party testing for hallucinationsD004: Third-party testing of tool calls
| No Gap | | AIS-06: Secure Application Deployment | Establish and implement strategies and capabilities for secure, standardized, and compliant application deployment. Automate where possible. |
C002: Conduct pre-deployment testingB008: Protect AI system deployment environmentD003: Restrict unsafe tool calls
| No Gap | | AIS-07: Application Vulnerability Remediation | Define and implement a process to remediate application security vulnerabilities, automating remediation when possible. |
C002: Conduct pre-deployment testingB001: Third-party testing of adversarial robustnessC006: Prevent output vulnerabilities
| **Partial Gap.** AIUC-1 vulnerability remediation requirements are focused on testing procedures | | AIS-08: Input Validation | Validate, filter, modify or block, as necessary, input against adversarial patterns, failure patterns and unwanted behaviour according to organisational policies and applicable laws and regulations. |
B002: Detect adversarial inputB001: Third-party testing of adversarial robustnessB005: Implement real-time input filtering
| No Gap | | AIS-09: Output Validation | Validate, filter, modify or block, as necessary, output against adversarial patterns, failure patterns and unwanted behaviour according to organisational policies and applicable laws and regulations. |
C004: Prevent out-of-scope outputsC006: Prevent output vulnerabilitiesC003: Prevent harmful outputsD001: Prevent hallucinated outputsD002: Third-party testing for hallucinationsA007: Prevent IP violationsB003: Manage public release of technical detailsB009: Limit output over-exposure
| No Gap | | AIS-10: API Security | Define and implement processes, procedures, and technical measures to secure APIs. Review and update for any improvements at least annually or after significant system changes. |
D003: Restrict unsafe tool callsB004: Prevent AI endpoint scrapingE009: Monitor third-party accessB002: Detect adversarial input
| No Gap | | AIS-11: Agents Security Boundaries | Establish security boundaries for agents. |
B006: Prevent unauthorized AI agent actionsA003: Limit AI agent data accessD003: Restrict unsafe tool calls
| No Gap | | AIS-12: Source Code Management | Implement source code management practices, such as version control, code review & static code analysis, aligning with the SDLC process. |
C002: Conduct pre-deployment testing
| No Gap | | AIS-13: AI Sandboxing | Implement sandboxing techniques to execute AI tools and
plugins in isolated environments to prevent unintended
interactions with critical systems or data and limit the
possibility of lateral movement. |
D003: Restrict unsafe tool calls
| **Partial Gap.** AIUC-1 does not require sandboxing techniques specifically, but require alternative safeguards | | AIS-14: AI Cache Protection | Implement security measures to protect caches in GenAI
systems and services. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 does not have specific controls for cache protection, but require system protection | | AIS-15: Prompt Differentiation | Implement mechanisms enabling the model to clearly distinguish user-provided input instructions from data and system instructions (e.g., system prompts). |
B003: Manage public release of technical detailsB005: Implement real-time input filtering
| **Full Gap.** Not covered in AIUC-1 | | BCR-01: Business Continuity Management Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain business continuity management and operational resilience policies and procedures.Review and update the policies and procedures at least annually, or when significant changes occur that could impact risk exposure. |
E008: Review internal processes
| **Full Gap.** Not covered specifically in AIUC-1 | | BCR-02: Risk Assessment and Impact Analysis | Determine the impact of business disruptions and risks to establish criteria for developing business continuity and operational resilience strategies and capabilities.Review and update the risk assessment and impact analysis at least annually or upon significant changes. |
C001: Define AI risk taxonomyE013: Implement quality management system
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | BCR-03: Business Continuity Strategy | Establish strategies to reduce the impact of business disruptions, and improve resiliency and recovery from business disruptions. | | **Full Gap.** Not covered specifically in AIUC-1 | | BCR-04: Business Continuity Planning | Establish, document, approve, communicate, apply, evaluate and maintaina business continuity plan based on the results of the operational resiliencestrategies and capabilities. | | **Full Gap.** Not covered specifically in AIUC-1 | | BCR-05: Documentation | Develop, identify, and acquire documentation, both internally and from external parties, that is relevant to support the business continuity and operational resilience programs. Make the documentation available to authorized stakeholders and review at least annually or upon significant changes. | | **Full Gap.** Not covered specifically in AIUC-1 | | BCR-06: Business Continuity Exercises | Follow a structured approach to evaluate the effectiveness of the business continuity and operational resilience plans at planned intervals or upon significant changes. | | **Full Gap.** Not covered specifically in AIUC-1 | | BCR-07: Communication | Establish and maintain communication channels with all relevant stakeholders in the course of business continuity and resilience procedures. | | **Full Gap.** Not covered specifically in AIUC-1 | | BCR-08: Backup | Periodically perform backups. Ensure the confidentiality, integrity and availability of the backup, and verify restoration from backup for resiliency. | | **Full Gap.** Outside the scope of AIUC-1 | | BCR-09: Disaster Response Plan | Establish, document, approve, communicate, apply, evaluate and maintaina disaster response plan to recover from natural and man-made disasters. Updatethe plan at least annually or upon significant changes. |
E001: AI failure plan for security breachesE002: AI failure plan for harmful outputsE003: AI failure plan for hallucinations
| **Full Gap.** Outside the scope of AIUC-1 | | BCR-10: Response Plan Exercise | Exercise the disaster response plan annually or upon significantchanges, including, if possible, participation of local emergency authorities. |
E001: AI failure plan for security breachesE002: AI failure plan for harmful outputsE003: AI failure plan for hallucinations
| **Partial Gap.** AIUC-1 does not require exercises | | BCR-11: Equipment Redundancy | Supplement business-critical equipment with both locally redundant and geographically dispersed equipment located at a reasonable minimum distance in accordance with applicable industry standards. | | **Full Gap.** Outside the scope of AIUC-1 | | CCC-01: Change Management Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for managing the risks associated with applying changes to assets owned, controlled or used by the organization. Review and update the policies and procedures at least annually, or upon significant changes. |
E007: \[Retired] Document system change approvalsE004: Assign accountability
| **Partial Gap.** AIUC-1 change management requirement is narrower in scope and limited to high-risk AI systems | | CCC-02: Quality Testing | Establish, maintain and implement a defined quality change control, approval and testing process incorporating baselines, testing, and release standards. |
C002: Conduct pre-deployment testingE013: Implement quality management system
| **Partial Gap.** AIUC-1 is focused on safety, security and reliability testing and does not have product quality in scope specifically | | CCC-03: Change Management Technology | Implement a change management procedure to manage the risks associated with applying changes to assets owned, controlled or used by the organization. |
E007: \[Retired] Document system change approvalsE004: Assign accountabilityC001: Define AI risk taxonomy
| No Gap | | CCC-04: Change Authorization | Implement and enforce a procedure to authorize addition, removal, update, and management of assets, owned, controlled or used by the organization. |
E007: \[Retired] Document system change approvals
| No Gap | | CCC-05: Change Agreements | Include provisions limiting changes directly impacting customer ownedenvironments/tenants to explicitly authorized requests within service level agreements. |
E007: \[Retired] Document system change approvalsE004: Assign accountability
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope - does not refer to SLAs specifically | | CCC-06: Change Management Baseline | Establish change management baselines for all relevant authorized changes on organization assets. Review and update the change management baseline at least annually or upon significant changes. |
E007: \[Retired] Document system change approvals
| **Full Gap.** Not covered specifically in AIUC-1 | | CCC-07: Detection of Baseline Deviation | Implement detection measures with proactive notification in case of changes deviating from the established baseline. | | **Full Gap.** Not covered specifically in AIUC-1 | | CCC-08: Exception Management | Implement a procedure for the management of exceptions, including emergencies, in the change and configuration process. Align the procedure withthe requirements of GRC-04: Policy Exception Process. | | **Full Gap.** Not covered specifically in AIUC-1 | | CCC-09: Change Restoration | Define and implement a process to proactively roll back changes to a previous known good state in case of errors or security concerns. |
E008: Review internal processes
| No Gap | | CEK-01: Encryption and Key Management Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for Cryptography, Encryption and Key Management. Review and update the policies and procedures at least annually or upon significant changes. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-02: CEK Roles and Responsibilities | Define and implement cryptographic, encryption and key managementroles and responsibilities. |
E004: Assign accountability
| No Gap | | CEK-03: Data Encryption | Provide data protection at-rest, in-transit and, where applicable, in-use by using cryptographic libraries certified to approved standards. |
B008: Protect AI system deployment environment
| No Gap | | CEK-04: Encryption Algorithm | Utilize encryption algorithms following industry standards for protecting data, based on the data classification and associated risks. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-05: Encryption Change Management | Establish a standard change management procedure, to accommodatechanges from internal and external sources, for review, approval, implementationand communication of cryptographic, encryption and key management technologychanges. | | No Gap | | CEK-06: Encryption Change Cost Benefit Analysis | Manage and adopt changes to cryptography-, encryption-, and key management-relatedsystems (including policies and procedures) that fully account for downstreameffects of proposed changes, including residual risk, cost, and benefits analysis. | | **Full Gap.** Outside the scope of AIUC-1 | | CEK-07: Encryption Risk Management | Establish and maintain an encryption and key management risk programthat includes provisions for risk assessment, risk treatment, risk context,monitoring, and feedback. |
C001: Define AI risk taxonomy
| **Partial Gap.** AIUC-1 requirement is less prescriptive and at a higher level | | CEK-08: Customer Key Management Capability | Providers must provide the capability for customers to manage their
own data encryption keys. | | **Full Gap.** Outside the scope of AIUC-1 | | CEK-09: Encryption and Key Management Audit | Audit encryption and key management systems, policies, and processeswith a frequency that is proportional to the risk exposure of the system withaudit occurring preferably continuously but at least annually and after anysecurity event(s). |
E008: Review internal processes
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-10: Key Generation | Generate Cryptographic keys using industry accepted cryptographiclibraries specifying the algorithm strength and the random number generatorused. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-11: Key Purpose | Manage cryptographic secret and private keys that are provisionedfor a unique purpose. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-12: Key Rotation | Rotate cryptographic keys in accordance with the calculated cryptoperiod,which includes provisions for considering the risk of information disclosureand legal and regulatory requirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-13: Key Revocation | Define, implement and evaluate processes, procedures and technicalmeasures to revoke and remove cryptographic keys prior to the end of its establishedcryptoperiod, when a key is compromised, or an entity is no longer part of theorganization, which include provisions for legal and regulatory requirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-14: Key Destruction | Define, implement, and evaluate processes, procedures, and technical measures to securely destroy cryptographic keys when they are no longer needed, which include provisions for legal and regulatory requirements.
|
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-15: Key Activation | Define, implement and evaluate processes, procedures and technicalmeasures to create keys in a pre-activated state when they have been generatedbut not authorized for use, which include provisions for legal and regulatoryrequirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-16: Key Suspension | Define, implement and evaluate processes, procedures and technicalmeasures to monitor, review and approve key transitions from any state to/fromsuspension, which include provisions for legal and regulatory requirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-17: Key Deactivation | Define, implement and evaluate processes, procedures and technicalmeasures to deactivate keys at the time of their expiration date, which includeprovisions for legal and regulatory requirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-18: Key Archival | Define, implement and evaluate processes, procedures and technicalmeasures to manage archived keys in a secure repository requiring least privilegeaccess, which include provisions for legal and regulatory requirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-19: Key Compromise | Define, implement and evaluate processes, procedures and technicalmeasures to use compromised keys to encrypt information only in controlled circumstance,and thereafter exclusively for decrypting data and never for encrypting data,which include provisions for legal and regulatory requirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-20: Key Recovery | Define, implement and evaluate processes, procedures and technicalmeasures to assess the risk to operational continuity versus the risk of thekeying material and the information it protects being exposed if control ofthe keying material is lost, which include provisions for legal and regulatoryrequirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | CEK-21: Key Inventory Management | Define, implement and evaluate processes, procedures and technicalmeasures in order for the key management system to track and report all cryptographic materials and changes in status, which include provisions for legal and regulatoryrequirements. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | DCS-01: Off-Site Equipment Disposal Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for the secure disposal of equipment used outside the organization's premises. If the equipment is not physically destroyed a data destruction procedure that renders recovery of information impossible must be applied. Review and update the policies and procedures at least annually, or upon significant changes. |
E005: Document data storage security
| **Full Gap.** Outside the scope of AIUC-1 | | DCS-02: Off-Site Transfer Authorization Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for the relocation or transfer of hardware, software,or data/information to an offsite or alternate location. The relocation or transferrequest requires the written or cryptographically verifiable authorization.Review and update the policies and procedures at least annually, or upon significant changes. |
E005: Document data storage security
| Full Gap | | DCS-03: Secure Area Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for maintaining a safe and secure working environmentin offices, rooms, and facilities. Review and update the policies and proceduresat least annually, or upon significant changes. |
E005: Document data storage security
| Full Gap | | DCS-04: Secure Media Transportation Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for the secure transportation of physical media. Review and update the policies and procedures at least annually, or upon significant changes. |
E005: Document data storage security
| Full Gap | | DCS-05: Assets Classification | Classify and document the physical, and logical assets (e.g., applications)based on the organizational business risk. Review and update the assets’ classification at least annually or upon significant changes. |
E005: Document data storage security
| Full Gap | | DCS-06: Assets Cataloguing and Tracking | Catalogue and track all relevant physical and logical assets locatedat all of the service providers sites within a secured system. Review and update the catalogue at least annually or upon significant changes. |
E005: Document data storage security
| Full Gap | | DCS-07: Controlled Physical Access Points | Design and implement physical security perimeters to safeguard personnel, data, and information systems. |
E005: Document data storage security
| Full Gap | | DCS-08: Equipment Identification | Use equipment identification as a method for connection authentication. |
E005: Document data storage security
| Full Gap | | DCS-09: Secure Area Authorization | Allow only authorized personnel access to secure areas, with allingress and egress points restricted, documented, and monitored by physicalaccess control mechanisms. Retain access control records on a periodic basisas deemed appropriate by the organization. |
E005: Document data storage security
| Full Gap | | DCS-10: Surveillance System | Implement, maintain, and operate datacenter surveillance systems at the external perimeter and at all the ingress and egress points to detect unauthorized ingress and egress attempts. |
E005: Document data storage security
| Full Gap | | DCS-11: Adverse Event Response Training | Train datacenter personnel to safely manage adverse events, including but not limited to unauthorized ingress and egress attempts. |
E005: Document data storage security
| Full Gap | | DCS-12: Cabling Security | Define, implement and evaluate processes, procedures and technical measures that ensure a risk-based protection of power and telecommunication cables from a threat of interception, interference or damage at all facilities, offices and rooms. |
E005: Document data storage security
| Full Gap | | DCS-13: Environmental Systems | Implement and maintain data center environmental control systems that monitor, maintain and test for continual effectiveness the temperatureand humidity conditions within accepted industry standards. |
E005: Document data storage security
| Full Gap | | DCS-14: Secure Utilities | Secure, monitor, maintain, and test utilities services for continualeffectiveness at planned intervals. |
E005: Document data storage security
| Full Gap | | DCS-15: Equipment Location | Keep business-critical equipment away from locations subject to high probability for environmental risk events. |
E005: Document data storage security
| Full Gap | | DSP-01: Security and Privacy Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for the classification, protection, preparation and handling of data throughout its lifecycle, and according to all applicable laws and regulations,standards, and risk level. Review and update the policies and procedures atleast annually. |
A004: Protect IP & trade secrets
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | DSP-02: Secure Disposal | Apply industry accepted methods for the secure disposal of data from storage media such that data is not recoverable by any forensic means. |
A004: Protect IP & trade secrets
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | DSP-03: Data Inventory | Create and maintain a data inventory, at least for any sensitive, regulated
and personal data. Review and update the inventory at least annually or upon significant changes. | | **Full Gap.** Not covered specifically in AIUC-1 | | DSP-04: Data Classification | Classify data according to its type and sensitivity level. | | **Full Gap.** Not covered specifically in AIUC-1 | | DSP-05: Data Flow Documentation | Create data flow documentation to identify what data is processed, stored or transmitted where. Review data flow documentation at defined intervals, at least annually, and after any change. | | **Full Gap.** Not covered specifically in AIUC-1 | | DSP-06: Data Ownership and Stewardship | Document ownership and stewardship of all relevant documented personal and sensitive data. Perform review at least annually. | | **Full Gap.** Not covered specifically in AIUC-1 | | DSP-07: Data Protection by Design and Default | Develop systems, products, and business practices based upon a principle of security by design and industry best practices. |
A004: Protect IP & trade secretsB007: Enforce user access privileges to AI systemsA003: Limit AI agent data accessB006: Prevent unauthorized AI agent actionsB008: Protect AI system deployment environment
| No Gap | | DSP-08: Data Privacy by Design and Default | Develop systems, products, and business practices based upon a principle of privacy by design and industry best practices. Ensure that systems' privacy settings are configured by default, according to all applicable laws and regulations. |
A004: Protect IP & trade secretsB007: Enforce user access privileges to AI systemsA002: Establish output data policyA003: Limit AI agent data access
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | DSP-09: Data Protection Impact Assessment | Conduct a Data Protection Impact Assessment (DPIA) to evaluate the origin, nature, particularity and severity of the risks upon the processing of personal data, according to any applicable laws, regulations and industrybest practices. |
E008: Review internal processesE013: Implement quality management systemC001: Define AI risk taxonomyA001: Establish input data policy
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | DSP-10: Sensitive Data Transfer | Define, implement and evaluate processes, procedures and technical measures that ensure any transfer of personal or sensitive data is protected from unauthorized access and only processed within scope as permitted by the respective laws and regulations. |
E012: Document regulatory complianceA004: Protect IP & trade secretsA006: Prevent PII leakage
| No Gap | | DSP-11: Personal Data Access, Reversal, Rectification and Deletion | Define and implement, processes, procedures and technical measures to enable data subjects to request access to, modification, or deletion of their personal data, according to any applicable laws and regulations. |
A001: Establish input data policy
| No Gap | | DSP-12: Limitation of Purpose in Personal Data Processing | Define, implement and evaluate processes, procedures and technical measures to ensure that personal data is processed according to any applicable laws and regulations and for the purposes declared to the data subject. |
A001: Establish input data policyA006: Prevent PII leakageA004: Protect IP & trade secrets
| No Gap | | DSP-13: Personal Data Sub-processing | Define, implement and evaluate processes, procedures and technical measures for the transfer and sub-processing of personal data within the service supply chain, according to any applicable laws and regulations. |
A001: Establish input data policyE011: Record processing locationsA006: Prevent PII leakage
| No Gap | | DSP-14: Disclosure of Data Sub-processors | Define, implement and evaluate processes, procedures and technical measures to disclose the details of any personal or sensitive data access by sub-processors to the data owner prior to initiation of that processing. |
A001: Establish input data policy
| No Gap | | DSP-15: Limitation of Production Data Use | Obtain authorization from data owners, and manage associated riskbefore replicating or using production data in non-production environments. |
A001: Establish input data policy
| No Gap | | DSP-16: Data Retention and Deletion | Data retention, archiving and deletion is managed in accordance withbusiness requirements, applicable laws and regulations. |
A001: Establish input data policyA002: Establish output data policyA004: Protect IP & trade secrets
| No Gap | | DSP-17: Sensitive Data Protection | Define and implement, processes, procedures and technical measuresto protect sensitive data throughout its lifecycle. |
A006: Prevent PII leakage
| No Gap | | DSP-18: Disclosure Notification | The providers should implement and describe to customers the procedure to manage and respond to requests for disclosure of Personal Data by Law Enforcement Authorities according to applicable laws and regulations.
|
E012: Document regulatory compliance
| No Gap | | DSP-19: Data Location | Define and implement, processes, procedures and technical measures to specify and document the physical locations of data, including any locations in which data is processed or backed up. |
E011: Record processing locations
| No Gap | | DSP-20: Data Provenance and Transparency | Define, implement and evaluate processes, procedures and technical measures to: 1) Document and trace data sources, and 2) Make the data source available according to legal and regulatory requirements |
A001: Establish input data policyE017: Document system transparency policy
| **Partial Gap.** AIUC-1 requirement is focused on model training data specifically | | DSP-21: Data Poisoning Prevention & Detection | Define, implement and evaluate processes, procedures and technical measures to prevent data poisoning in AI models and continuously detect such. | | **No Gap.** AIUC-1 control activities recommend "detecting and removing poisoned or malicious data, validating data integrity and source authenticity." | | DSP-22: Privacy Enhancing Technologies | Use Privacy Enhancing Technologies for training data, informed by risk and privacy impact analysis and business use cases. |
A005: Prevent cross-customer data exposureA003: Limit AI agent data access
| **Partial Gap.** AIUC-1 does not specifically require Privacy Enhancing Technologies for AI training data | | DSP-23: Data Integrity Check | Regularly validate the consistency and conformity of training, fine-tuning or augmentation data. Implement dataset versioning to ensure traceability and enforce restrictions to prevent unauthorized changes. |
A001: Establish input data policy
| **Partial Gap.** AIUC-1 does not require version control systems for datasets or access restrictions and authorization for training data changes | | DSP-24: Data Differentiation and Relevance | Ensure training-data differentiation and relevance to the intended use of the AI Model. | | **Partial Gap.** AIUC-1 requirements does not specify differentiation specifically | | GRC-01: Governance Program Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for an information governance program, which is sponsored by the leadership of the organization and related to AI systems as well. Review and update the policies and procedures at least annually. | | **Full Gap.** AIUC-1 does not require a governance policy specifically | | GRC-02: Risk Management Program | Establish and maintain a formal, documented, and leadership-sponsored
AI Risk Management (AIRM) program that includes policies and
procedures for identification, evaluation, ownership, treatment, and
acceptance of risks. |
C001: Define AI risk taxonomyC008: Monitor AI risk categoriesE013: Implement quality management systemF001: Prevent AI cyber misuseF002: Prevent catastrophic misuse
| No Gap | | GRC-03: Organizational Policy Reviews | Review all relevant organizational policies and associated proceduresat least annually or when a substantial change occurs within the organization. |
E008: Review internal processes
| No Gap | | GRC-04: Policy Exception Process | Establish and follow an approved exception process as mandated bythe governance program whenever a deviation from an established policy occurs. | | **Full Gap.** AIUC-1 does not have requirements on policy exceptions specifically | | GRC-05: Information Security Program | Develop and implement an Information Security Program, which includesprograms for all the relevant domains of the AICM. | | **Full Gap.** Not covered specifically in AIUC-1 | | GRC-06: Governance Responsibility Model | Define and document roles and responsibilities for planning, implementing,operating, assessing, and improving governance programs. |
E004: Assign accountability
| **Full Gap.** AIUC-1 requires assigning accountability for system changes, but not governance programs specifically | | GRC-07: Information System Regulatory Mapping | Identify and document all relevant standards, regulations, legal/contractual, and statutory requirements, which are applicable to your organization. Review at least annually or when a substantial change occurs within the organization. |
E012: Document regulatory compliance
| No Gap | | GRC-08: Special Interest Groups | Establish and maintain contact with related special interest groups and other relevant entities in line with business context. | | **Full Gap.** Outside the scope of AIUC-1 | | GRC-09: Acceptable Use of the AI Service | Define, document and enforce policies and procedures on the acceptable use of AI services offered by the organization. Ensure effectiveness by continuous risk assessments, reviews and human oversight. |
E010: Establish AI acceptable use policyC003: Prevent harmful outputsC004: Prevent out-of-scope outputsC005: Prevent agent-specific high risk outputsF001: Prevent AI cyber misuseF002: Prevent catastrophic misuse
| No Gap | | GRC-10: AI Impact Assessment | Establish, document, and communicate to all relevant stakeholders an AI Impact Assessment process and its criteria to regularly evaluate the ethical, societal, operational, legal, and security impacts of the AI system throughout its lifecycle.
|
E013: Implement quality management systemF001: Prevent AI cyber misuseF002: Prevent catastrophic misuse
| **Full Gap.** AIUC-1 does not explicitly require AI impact assessments for all AI systems | | GRC-11: Bias and Fairness Assessment | Regularly evaluate AI systems, models, datasets & algorithms for bias and fairness to ensure compliance with ethical standards. |
C003: Prevent harmful outputsC010: Third-party testing for harmful outputs
| No Gap | | GRC-12: Ethics Committee | Establish an ethics committee to review AI applications, ensuring alignment with ethical standards and organizational values. |
F001: Prevent AI cyber misuseF002: Prevent catastrophic misuse
| **Full Gap.** Not covered specifically in AIUC-1 | | GRC-13: Explainability Requirement | Establish, document, and communicate the degree of
explainability needed for the AI Services. |
E017: Document system transparency policy
| **Partial Gap.** AIUC-1 requirement is less prescriptive | | GRC-14: Explainability Evaluation | Evaluate, document, and communicate the degree of
explainability of the AI Services, including possible limitations
and exceptions. |
E017: Document system transparency policyE014: \[Retired] Share transparency reports
| No Gap | | GRC-15: Human supervision | Establish, execute, and assess processes, procedures, and technical measures to ensure human oversight and control of the AI system in compliance with regulatory requirements and organizational risk management. |
C007: Flag high risk outputs for human reviewE016: Implement AI disclosure mechanismsC009: Enable real-time feedback and intervention
| No Gap | | HRS-01: Background Screening Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for background verification of all new employees (includingbut not limited to remote employees, contractors, and third parties) accordingto local laws, regulations, ethics, and contractual constraints and proportionalto the data classification to be accessed, the business requirements, and acceptablerisk. Review and update the policies and procedures at least annually. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-02: Acceptable Use of Technology Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for defining allowances and conditions for the acceptable use of organizationally-owned or managed assets. Review and update the policiesand procedures at least annually. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-03: Clean Desk Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures that require unattended workspaces to not have openlyvisible confidential data. Review and update the policies and procedures atleast annually. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-04: Remote and Home Working Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures to protect information accessed, processed or storedat remote sites and locations. Review and update the policies and proceduresat least annually. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-05: Asset returns | Establish and document procedures for the return of organization-ownedassets by terminated employees. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-06: Employment Termination | Establish, document, and communicate to all personnel the proceduresoutlining the roles and responsibilities concerning changes in employment. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-07: Employment Agreement Process | Employees sign the employee agreement prior to being granted accessto organizational information systems, resources and assets. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-08: Employment Agreement Content | The organization includes within the employment agreements provisionsand/or terms for adherence to established information governance and securitypolicies. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-09: Personnel Roles and Responsibilities | Document and communicate roles and responsibilities of employees,as they relate to information assets and security. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-10: Non-Disclosure Agreements | Identify, document, and review, at planned intervals, requirementsfor non-disclosure/confidentiality agreements reflecting the organization'sneeds for the protection of data and operational details. |
E012: Document regulatory compliance
| **Full Gap.** Outside the scope of AIUC-1 | | HRS-11: Security Awareness Training | Establish, document, approve, communicate, apply, evaluate and maintain a security awareness training program for all employees of the organization and provide regular training updates. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-12: Personal and Sensitive Data Awareness and Training | Provide employees with access to sensitive organizational and
personal data with appropriate security awareness training and regular
updates in organizational procedures, processes, and policies relating
to their professional function relative to the organization.
|
A006: Prevent PII leakage
| **Full Gap.** Outside the scope of AIUC-1 | | HRS-13: Compliance User Responsibility | Make employees aware of their roles and responsibilities for maintaining awareness and compliance with established policies and procedures and applicablelegal, statutory, or regulatory compliance obligations. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-14: AI Competency Training | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures defining the AI training program for all relevant personnel of the organization based on their roles and provide regular training updates. | | **Full Gap.** Outside the scope of AIUC-1 | | HRS-15: AI Acceptable Use | Establish, document, and communicate to all personnel the policies and procedures on the acceptable use of AI technologies within the organization. | | **Full Gap.** Outside the scope of AIUC-1 | | I\&S-01: Infrastructure and Virtualization Security Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for infrastructure and virtualization security. Reviewand update the policies and procedures at least annually, or upon significant changes. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-02: Capacity and Resource Planning | Plan and monitor the availability, quality, and adequate capacityof resources in order to deliver the required system performance as determinedby the business. |
E013: Implement quality management system
| **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-03: Network Security | Monitor, encrypt and restrict communications between environmentsto only authenticated and authorized connections, as justified by the business.Review these configurations at least annually, and support them by a documentedjustification of all allowed services, protocols, ports, and compensating controls. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-04: OS Hardening and Base Controls | Harden host and guest OS, hypervisor or infrastructure control planeaccording to their respective best practices, and supported by technical controls,as part of a security baseline. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-05: Production and Non-Production Environments | Separate production and non-production environments. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-06: Segmentation and Segregation | Design, develop, deploy and configure applications and infrastructures such that tenant access is appropriately segmented and segregated, monitored and restricted. |
A005: Prevent cross-customer data exposure
| **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-07: Migration to Hosted Environments | Use secure and encrypted communication channels when migrating servers, services, applications, or data to hosted environments. Such channels must include only up-to-date and approved protocols. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-08: Network Architecture Documentation | Identify and document high-risk environments. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | I\&S-09: Network Defense | Define, implement and evaluate processes, procedures and defense-in-depthtechniques for protection, detection, and timely response to network-based attacks. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | IAM-01: Identity and Access Management Policy and Procedures | Establish, document, approve, communicate, implement, apply, evaluateand maintain policies and procedures for identity and access management. Reviewand update the policies and procedures at least annually, or upon significant changes. |
B007: Enforce user access privileges to AI systems
| **Partial Gap.** AIUC-1 covers identity and access management procedures but not policy creation and maintenance | | IAM-02: Strong Password Policy and Procedures | Establish, document, approve, communicate, implement, apply, evaluateand maintain strong password policies and procedures. Review and update thepolicies and procedures at least annually. |
B007: Enforce user access privileges to AI systems
| **Full Gap.** Outside the scope of AIUC-1 | | IAM-03: Identity Inventory | Manage, store, and regularly review the inventory of identities, and monitor their level of access. |
B007: Enforce user access privileges to AI systemsE008: Review internal processes
| No Gap | | IAM-04: Separation of Duties | Employ the separation of duties principle when implementing information system access. |
B007: Enforce user access privileges to AI systemsB008: Protect AI system deployment environment
| No Gap | | IAM-05: Least Privilege | Employ the least privilege principle when implementing information system access. |
B007: Enforce user access privileges to AI systems
| No Gap | | IAM-06: User Access Provisioning | Define and implement an identity access provisioning process which authorizes, records, and communicates access changes to data and assets. |
B007: Enforce user access privileges to AI systems
| No Gap | | IAM-07: User Access Changes and Revocation | De-provision or modify identity access in a timely manner. |
B007: Enforce user access privileges to AI systems
| No Gap | | IAM-08: User Access Review | Review and revalidate user access for least privilege and separationof duties with a frequency that is commensurated with organizational risk tolerance and at least annually, or upon significant changes. |
B007: Enforce user access privileges to AI systemsE008: Review internal processes
| No Gap | | IAM-09: Segregation of Privileged Access Roles | Define, implement and evaluate processes, procedures and technical measures for the segregation of privileged access roles. |
B007: Enforce user access privileges to AI systems
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | IAM-10: Management of Privileged Access Roles | Define and implement an access process to ensure privileged accessroles and rights are granted for a time limited period, and implement procedures to prevent the accumulation of segregated privileged access. |
B007: Enforce user access privileges to AI systems
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | IAM-11: Customers' Approval for Agreed Privileged Access Roles | Define, implement and evaluate processes and procedures for customers to participate, where applicable, in the granting of access for agreed, highrisk (as defined by the organizational risk assessment) privileged access roles. | | **Full Gap.** Outside the scope of AIUC-1 | | IAM-12: Safeguard Logs Integrity | Define, implement and evaluate processes, procedures and technical measures to ensure the logging infrastructure is read-only for all with write access, including privileged access roles, and that the ability to disable it's controlled through a procedure that ensures the segregation of duties and break glass procedures. | | **Full Gap.** Outside the scope of AIUC-1 | | IAM-13: Uniquely Identifiable Users | Define, implement and evaluate processes, procedures and technical measures, that ensure identities’ activities are identifiable through uniquely associated IDs.
|
B007: Enforce user access privileges to AI systems
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | IAM-14: Strong Authentication | Define, implement and evaluate processes, procedures and technical measures for authenticating access to systems, application and data assets, including multifactor authentication for at least privileged user and sensitive data access. Adopt digital certificates or alternatives which achieve an equivalent level of security for system identities. |
B007: Enforce user access privileges to AI systemsB008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | IAM-15: Passwords and Secrets Management | Define, implement and evaluate processes, procedures and technical measures for the secure management of passwords and other secrets. |
B007: Enforce user access privileges to AI systems
| **Full Gap.** Outside the scope of AIUC-1 | | IAM-16: Authorization Mechanisms | Define, implement and evaluate processes, procedures and technicalmeasures to verify access to data and system functions is authorized. |
B007: Enforce user access privileges to AI systems
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | IAM-17: Knowledge Access Control - Need to Know | Define policy and procedure for "need to know" access to knowledge, information and data within the organization and in the context of the AI system to be applied when regulating access to resources. |
B007: Enforce user access privileges to AI systemsA003: Limit AI agent data access
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | IAM-18: Output Modification and Special Authorization | When allowing model output modification of AI generated output, establish a role for this access and allow changes only by authorized identities. |
B007: Enforce user access privileges to AI systems
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | IAM-19: Agent Access Restriction | Restrict agents' access to the tools and plugins necessary for the activity or use case at hand, ensuring adherence to the principles of need-to-know and least privilege. |
B006: Prevent unauthorized AI agent actionsA003: Limit AI agent data access
| No Gap | | IPY-01: Interoperability and Portability Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for interoperability and portability includingrequirements for:a. Communications between application interfacesb. Information processing interoperabilityc. Application development portabilityd. Information/Data exchange, usage, portability, integrity, and persistenceReview and update the policies and procedures at least annually or upon significant changes. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | IPY-02: Application Interface Availability | Provide application interface(s) to AICs so that they programmatically retrieve their data to enable interoperability and portability. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | IPY-03: Secure Interoperability and Portability Management | Implement cryptographically secure and standardized network protocolsfor the management, import and export of data, according to industry standards. | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | IPY-04: Data Portability Contractual Obligations | Agreements must include provisions specifying AICs access to dataupon contract termination and will include:a. Data formatb. Length of time the data will be storedc. Scope of the data retained and made available to the AICsd. Data deletion policy | | **Full Gap.** Outside the scope of AIUC-1 as it does not cover classic cyber security practices | | LOG-01: Logging and Monitoring Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and
maintain policies and procedures for logging and monitoring. Review
and update the policies and procedures at least annually, or upon significant changes.
|
E015: Log AI system activity
| **Partial Gap.** AIUC-1 covers logging procedures but not policy creation | | LOG-02: Audit Logs Protection | Define, implement and evaluate processes, procedures and technical measures to ensure the security and retention of audit logs. | | **Partial Gap.** AIUC-1 requirements are focused on PII logs specifically | | LOG-03: Security Monitoring and Alerting | Identify and monitor security-related events within applications, the underlying infrastructure, supply chain, and consider logging other events based on risk evaluation. Define and implement a system to generate alerts to responsible stakeholders based on such events and corresponding metrics. |
E015: Log AI system activity
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | LOG-04: Audit Logs Access and Accountability | Restrict access to audit logs and maintain records of access to logs. |
B007: Enforce user access privileges to AI systemsE015: Log AI system activity
| No Gap | | LOG-05: Audit Logs Monitoring and Response | Monitor security audit logs to detect activity outside of typical or expected patterns. Establish and follow a defined process to review and take appropriate and timely actions on detected anomalies. |
E009: Monitor third-party accessE015: Log AI system activity
| **Partial Gap.** AIUC-1 monitoring covers account information access but not security audit log monitoring for unusual activity across all systems | | LOG-06: Clock Synchronization | Use a reliable time source across all relevant information processing systems. |
E015: Log AI system activity
| **Full Gap.** Not covered specifically in AIUC-1 | | LOG-07: Logging Scope | Establish, document and implement which information meta/data system events should be logged. Review and update the scope at least annually or whenever there is a change in the threat environment. |
E015: Log AI system activityE008: Review internal processes
| No Gap | | LOG-08: Log Records | Generate audit records containing relevant security information. |
E015: Log AI system activity
| No Gap | | LOG-09: Log Protection | Protect audit records from unauthorized access, modification,
and deletion. |
E015: Log AI system activityB007: Enforce user access privileges to AI systems
| No Gap | | LOG-10: Encryption Monitoring and Reporting | Establish and maintain a monitoring and internal reporting capability over the operations of cryptographic, encryption and key management policies, processes, procedures, and controls. |
E015: Log AI system activityE014: \[Retired] Share transparency reports
| **Partial Gap.** AIUC-1 does not require monitoring of encryption specifically | | LOG-11: Transaction / Activity Logging | Log and monitor key lifecycle management events to enable auditing and reporting on usage of cryptographic keys. |
E015: Log AI system activity
| **Partial Gap.** AIUC-1 does not cover reporting on usage of cryptographic keys specifically | | LOG-12: Access Control Logs | Monitor and log physical access using an auditable access control system. |
B007: Enforce user access privileges to AI systemsE015: Log AI system activity
| **Full Gap.** Outside the scope of AIUC-1 | | LOG-13: Failures and Anomalies Reporting | Define, implement and evaluate processes, procedures and technical measures for the reporting of anomalies and failures of the monitoring system and provide immediate notification to the accountable party. |
E015: Log AI system activityE014: \[Retired] Share transparency reports
| **Full Gap.** AIUC-1 does not require reporting on failures of the monitoring system specifically | | LOG-14: Input Monitoring | Log and monitor all input events (content and metadata) to enable auditing and reporting on the usage of AI models. |
B005: Implement real-time input filteringE015: Log AI system activityB002: Detect adversarial input
| **Partial Gap.** AIUC-1 does not require all input to be logged | | LOG-15: Output Monitoring | Log and monitor all output events (content and metadata) to enable auditing and reporting on usage of AI models. |
E015: Log AI system activityC003: Prevent harmful outputsC004: Prevent out-of-scope outputsC005: Prevent agent-specific high risk outputs
| No Gap | | MDS-01: Training Pipeline Security | Define, implement, and evaluate policies, procedures, and technical measures that ensure the security of the Training Pipeline. Regularly review and update policies, procedures and technical measures to address new security threats and best practices. |
B008: Protect AI system deployment environment
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | MDS-02: Model Artifact Scanning | Define, implement, and evaluate policies, procedures, and technical measures for the scanning of model artifacts for vulnerabilities and attacks, at each step of the service lifecycle and at each hand over point. Regularly review and update policies, procedures and technical measures to address model artifact scanning. |
B008: Protect AI system deployment environmentE013: Implement quality management system
| **Partial Gap.** Model scanning is recommended as part of AIUC-1 control activities | | MDS-03: Model Documentation | Define, implement, enforce, approve, document, communicate, maintain and evaluate processes and procedures for model documentation.Regularly review and update the model documentation. |
E017: Document system transparency policy
| No Gap | | MDS-04: Model Documentation Requirements | Establish and implement baseline requirements for Model documentation. |
E017: Document system transparency policyA003: Limit AI agent data access
| No Gap | | MDS-05: Model Documentation Validation | Define, implement, and evaluate processes, procedures, and technical measures for the validation of the Model documentation aligned with the current model. |
E017: Document system transparency policy
| **Partial Gap.** AIUC-1 does not require validation specifically | | MDS-06: Adversarial Attack Analysis | Define, implement, and evaluate processes and technical measures to assess adversarial threats specific to each AI model. |
B001: Third-party testing of adversarial robustnessD002: Third-party testing for hallucinations
| No Gap | | MDS-07: Robustness against Adversarial Attack / Model Hardening | Define, implement, and evaluate processes, procedures, and technicalmeasures for Model Hardening to mitigate relevant adversarial attacks as identified in the Threat Analysis and Adversarial Threat Analysis. |
B001: Third-party testing of adversarial robustnessB002: Detect adversarial inputD002: Third-party testing for hallucinations
| No Gap | | MDS-08: Model Integrity Checks | Regularly calculate and compare checksums using cryptographic hashes of model checkpoints to detect unauthorized modifications. Apply at least annually based on the level of risk, or after any change of hands. |
B008: Protect AI system deployment environment
| **No Gap.** AIUC-1 control activities recommend verifying model integrity before and during deployment. For example, using cryptographic checksum | | MDS-09: Model Signing/Ownership Verification | Sign models cryptographically and verify signatures to ensure model provenance and ownership, any time the model changes hands or is loaded from storage. |
B008: Protect AI system deployment environmentE004: Assign accountability
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | MDS-10: Model Continuous Monitoring | Define, implement, and evaluate processes, procedures, and technical measures for continuous monitoring of model performance metrics over time to identify sudden shifts or unexpected changes in predictions that could degrade model performance. |
E015: Log AI system activityD001: Prevent hallucinated outputsD003: Restrict unsafe tool calls
| No Gap | | MDS-11: Model Failure | Perform a risk-based evaluation of the model and model serving infrastructure for model failure.Define and implement measures to mitigate model and model serving infrastructure failures, and regularly evaluate throughout the AI system's lifecycle. |
C001: Define AI risk taxonomyC008: Monitor AI risk categoriesD001: Prevent hallucinated outputsD003: Restrict unsafe tool calls
| No Gap | | MDS-12: Open Model Risk Assessment | Establish a process to evaluate risk associated with open models. Periodically review these risk factors, and implement a process to monitor and mitigate any determined vulnerabilities. |
C001: Define AI risk taxonomyC008: Monitor AI risk categories
| **Partial Gap.** AIUC-1 requires risk evaluation of open models across a number of areas including cyber misuse, catastrophic misuse and IP violations | | MDS-13: Secure Model Format | Adopt secure model formats and processes for AI model serialization where applicable. | | **Full Gap.** AIUC-1 only covers model deployment environment, not the model format itself | | SEF-01: Security Incident Management Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintainpolicies and procedures for Security Incident Management, E-Discovery, and Forensics. Review and update the policies and procedures at least annually or upon significant changes. |
E001: AI failure plan for security breachesE013: Implement quality management system
| No Gap | | SEF-02: Service Management Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for the timely management of security incidents. Review and update the policies and procedures at least annually, or upon significant changes. |
E001: AI failure plan for security breaches
| No Gap | | SEF-03: Incident Response Plans | Establish, document, approve, communicate, apply, evaluate and maintain a security incident response plan, which includes but is not limited to: a communication strategy for notifying relevant internal departments, impacted AICs, and other business critical relationships (such as supply-chain) that may be impacted. |
E001: AI failure plan for security breaches
| No Gap | | SEF-04: Incident Response Testing | Follow a structured approach to evaluate the effectiveness of incident response plans at planned intervals or upon significant changes. |
E001: AI failure plan for security breaches
| **Full Gap.** AIUC-1 does not require testing of incident response | | SEF-05: Incident Response Metrics | Establish, monitor and report information security incident
metrics. |
E001: AI failure plan for security breachesE014: \[Retired] Share transparency reportsE015: Log AI system activity
| **Full Gap.** AIUC-1 does not require metrics specifically | | SEF-06: Event Triage Processes | Define, implement and evaluate processes, procedures and technical measures supporting business processes to triage security-related events. | | **Full Gap.** Not covered specifically in AIUC-1 | | SEF-07: Security Breach Notification | Define and implement, processes, procedures and technical measuresfor security breach notifications. Report material security breaches and assumed security breaches including any relevant supply chain breaches, as per applicable SLAs, laws and regulations. |
E001: AI failure plan for security breachesE014: \[Retired] Share transparency reportsE015: Log AI system activity
| No Gap | | SEF-08: Points of Contact Maintenance | Maintain points of contact for applicable regulation authorities,national and local law enforcement, and other legal jurisdictional authorities. Review and update the points of contact at least annually. |
E001: AI failure plan for security breaches
| **Partial Gap.** AIUC-1 does not require points of contact for all of the categories mentioned in the control | | SEF-09: Incident Response | Define incident categories and severity levels for AI systems, and determine response procedures for each, including automated response where applicable. |
E001: AI failure plan for security breachesE002: AI failure plan for harmful outputsE003: AI failure plan for hallucinations
| No Gap | | STA-01: Supply Chain Risk Management Policies and Procedures | Establish, document, approve, communicate, apply, evaluate, and maintain policies and procedures for supply chain risk management. Review and update the policies and procedures at least annually or upon significant changes. |
E006: Conduct vendor due diligence
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | STA-02: SSRM Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for the application of the Shared Security Responsibility Model (SSRM) within the organization. Review and update the policies and procedures at least annually, or upon significant changes. | | **Full Gap.** Not covered specifically in AIUC-1 | | STA-03: SSRM Supply Chain | Apply, document, implement and manage the SSRM throughout the supply chain. | | **Full Gap.** Not covered specifically in AIUC-1 | | STA-04: SSRM Guidance | Provide SSRM Guidance to the Customer detailing information about theSSRM applicability throughout the supply chain. | | **Full Gap.** Not covered specifically in AIUC-1 | | STA-05: SSRM Control Ownership | Delineate the shared ownership and applicability of all CSA AICM controls according to the SSRM. | | **Full Gap.** Outside the scope of AIUC-1 | | STA-06: SSRM Documentation Review | Review and validate SSRM documentation. | | **Full Gap.** Not covered specifically in AIUC-1 | | STA-07: SSRM Control Implementation | Implement, operate, and audit or assess the portions of the SSRM which the organization is responsible for. | | **Full Gap.** Not covered specifically in AIUC-1 | | STA-08: Supply Chain Inventory | Develop and maintain an inventory of all supply chain relationships. |
E006: Conduct vendor due diligence
| **Full Gap.** Outside the scope of AIUC-1 | | STA-09: Supply Chain Risk Management | Periodically review risk factors associated with supply chain relationships. |
E006: Conduct vendor due diligence
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | STA-10: Primary Service and Contractual Agreement | 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 |
E006: Conduct vendor due diligenceA002: Establish output data policyC005: Prevent agent-specific high risk outputs
| **Full Gap.** Outside the scope of AIUC-1 | | STA-11: Supply Chain Agreement Review | Review supply chain agreements at least annually, or upon significant changes. |
E006: Conduct vendor due diligence
| **Full Gap.** Outside the scope of AIUC-1 | | STA-12: Supply Chain
Compliance
Assessment
| Define and implement a process for conducting internal assessments to confirm conformance and effectiveness of standards, policies, procedures, and service level agreement activities at least annually. |
E006: Conduct vendor due diligence
| **Partial Gap.** AIUC-1 does not require annual internal assessments of supply chain compliance | | STA-13: Supply Chain Service Agreement Compliance
| Implement policies requiring all service providers throughout the supply chain to comply with information security, confidentiality, access control, privacy, audit, personnel policy and service level requirements and standards.
|
E006: Conduct vendor due diligence
| **Full Gap.** Outside the scope of AIUC-1 | | STA-14: Supply Chain Governance Review | Periodically review the organization's supply chain partners' IT governance policies and procedures. |
E006: Conduct vendor due diligence
| **Full Gap.** Outside the scope of AIUC-1 | | STA-15: Supply Chain Data Security Assessment | Define and implement a process for conducting security assessments periodically for all organizations within the supply chain. |
E006: Conduct vendor due diligence
| **Full Gap.** Outside the scope of AIUC-1 | | STA-16: Service Bill of Material (BOM) | Define, implement, and enforce a process for establishing a Bill of Material for the service supply chain. Review and update the Bill of Material at least annually or upon significant changes.
|
E017: Document system transparency policy
| **Full Gap.** AIUC-1 does not have a specific BOM requirement, but requires core AI system elements to be documented in other requirements | | TVM-01: Threat and Vulnerability Management Policy and Procedures | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures to identify, report and prioritize the remediation of vulnerabilities and threats, in order to protect systems against vulnerability exploitation. Review and update the policies and procedures at least annually or upon significant changes. |
B002: Detect adversarial inputB001: Third-party testing of adversarial robustnessE013: Implement quality management system
| **Partial Gap.** AIUC-1 requirements focus on adversarial input detection and regular testing of adversarial robustness | | TVM-02: Malware and Malicious Instructions Protection Policy and Procedure | Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures to protect against malware and malicious instructions. Review and update the policies and procedures at least annually or upon significant changes. |
C006: Prevent output vulnerabilitiesB002: Detect adversarial inputE013: Implement quality management system
| No Gap | | TVM-03: Vulnerability Remediation Schedule | Define, implement and evaluate processes, procedures and technical measures to enable both scheduled and emergency responses to vulnerability identifications, based on the identified risk. |
B001: Third-party testing of adversarial robustnessC008: Monitor AI risk categories
| No Gap | | TVM-04: Detection Updates | Define, implement and evaluate processes, procedures and technical measures to update detection tools, threat signatures, and indicators of compromise on a weekly, or more frequent basis. |
B002: Detect adversarial input
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | TVM-05: External Library Vulnerabilities | Define, implement and evaluate processes, procedures and technical measures to identify updates for applications which use third party or open-source libraries according to the organization's vulnerability management policy. |
B001: Third-party testing of adversarial robustnessC002: Conduct pre-deployment testingE009: Monitor third-party access
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | TVM-06: Penetration Testing | Define, implement and evaluate processes, procedures and technicalmeasures for the periodic performance of penetration testing by independentthird parties. |
B001: Third-party testing of adversarial robustnessB004: Prevent AI endpoint scrapingC010: Third-party testing for harmful outputsC012: Third-party testing for customer-defined risk
| No Gap | | TVM-07: Vulnerability Remediation Schedule | Define, implement and evaluate processes, procedures and technical measures based on identified risks to support scheduled and emergency responses to vulnerability identification. |
B001: Third-party testing of adversarial robustnessC008: Monitor AI risk categories
| No Gap | | TVM-08: Vulnerability Prioritization | Use a risk-based model for effective prioritization of vulnerabilityremediation using an industry recognized framework. |
B001: Third-party testing of adversarial robustness
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | TVM-09: Vulnerability Management Reporting | Define and implement a process for tracking and reporting vulnerabilityidentification and remediation activities that includes stakeholder notification. |
E014: \[Retired] Share transparency reports
| No Gap | | TVM-10: Vulnerability Management Metrics | Establish, monitor and report metrics for vulnerability identificationand remediation at defined intervals. |
E014: \[Retired] Share transparency reports
| No Gap | | TVM-11: Guardrails | Define and implement processes, procedures and technical measures to
apply guardrails to the AI system.
Continuously evaluate guardrails for changes in regulatory requirements
and risk scenarios.
|
C003: Prevent harmful outputsC004: Prevent out-of-scope outputsC005: Prevent agent-specific high risk outputsD003: Restrict unsafe tool callsF001: Prevent AI cyber misuseF002: Prevent catastrophic misuse
| No Gap | | TVM-12: Threat Analysis and Modeling | Define implement and evaluate threat analysis process and procedures to identify, assess and review the threat landscape for Cloud and AI systems. Build threat models according to industry best practices to inform the risk mitigation strategy. |
B001: Third-party testing of adversarial robustnessD003: Restrict unsafe tool calls
| **Partial Gap.** AIUC-1 does not cover cloud systems, but is focused on AI systems specifically | | TVM-13: Threat Response | Use a risk-based method for the prioritization and mitigation of threats, leveraging an industry-recognized framework to guide threat decision-making and protection measures. |
B001: Third-party testing of adversarial robustness
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | UEM-01: Endpoint Devices Policy and Procedures | Establish, document, approve, communicate, apply, evaluate
and maintain policies and procedures for all endpoints.
Review and update the policies and procedures at least
annually or uponsignificant system changes. |
B004: Prevent AI endpoint scraping
| **Partial Gap.** AIUC-1 requirement is smaller in scope | | UEM-02: Application and Service Approval | Define, document, apply and evaluate a list of approved services, applications and sources of applications (stores) acceptable for use by endpoints when accessing or storing organization-managed data. | | **Full Gap.** Outside the scope of AIUC-1 | | UEM-03: Compatibility | Define and implement a process for the validation of the endpoint device's compatibility with operating systems and applications. | | **Full Gap.** Not covered specifically in AIUC-1 | | UEM-04: Endpoint Inventory | Maintain an inventory of all endpoints used to store and process
company data.
|
E011: Record processing locations
| **Partial Gap.** Endpoint inventory is not required specifically by AIUC-1 | | UEM-05: Endpoint Management | Define, implement and evaluate processes, procedures and technical measures to enforce policies and controls for all endpoints permitted to acces ssystems and/or store, transmit, or process organizational data. |
B004: Prevent AI endpoint scraping
| **Partial Gap.** AIUC-1 requirement is less prescriptive and smaller in scope | | UEM-06: Automatic Lock Screen | Configure all relevant interactive-use endpoints to require an automaticlock screen. | | **Full Gap.** Outside the scope of AIUC-1 | | UEM-07: Operating Systems | Manage changes to endpoint operating systems, patch levels, and/orapplications through the company's change management processes. | | **Full Gap.** Outside the scope of AIUC-1 | | UEM-08: Storage Encryption | Protect information from unauthorized disclosure on managed endpoint devices with storage encryption. |
B008: Protect AI system deployment environmentA004: Protect IP & trade secretsA005: Prevent cross-customer data exposureA006: Prevent PII leakage
| No Gap | | UEM-09: Anti-Malware Detection and Prevention | Configure managed endpoints with anti-malware detection and prevention technology and services. |
B002: Detect adversarial inputB004: Prevent AI endpoint scraping
| No Gap | | UEM-10: Software Firewall | Configure managed endpoints with properly configured software firewalls. |
B004: Prevent AI endpoint scraping
| No Gap | | UEM-11: Data Loss Prevention | Configure managed endpoints with Data Loss Prevention (DLP) technologiesand rules in accordance with a risk assessment. |
B004: Prevent AI endpoint scraping
| **Full Gap.** AIUC-1 requirement does not address DLP requirements specifically | | UEM-12: Remote Locate | Enable remote geo-location capabilities for all managed mobile endpoints,
according to all applicable laws and regulations.
| | **Full Gap.** Outside the scope of AIUC-1 | | UEM-13: Remote Wipe | Define, implement and evaluate processes, procedures and technicalmeasures to enable the deletion of company data remotely on managed endpointdevices. | | **Full Gap.** Outside the scope of AIUC-1 | | UEM-14: Third-Party Endpoint Security Posture | Define, implement and evaluate processes, procedures and technicaland/or contractual measures to maintain proper security of third-party endpointswith access to organizational assets. |
E009: Monitor third-party accessB004: Prevent AI endpoint scraping
| **Partial Gap.** AIUC-1 requires monitoring third-party access and endpoint scraping protection, but does not require specific measures on third-party endpoints | Last updated September 18, 2025.
37.782274° N -122.392147° W FIG. A (SITE INDEX)
Artificial Intelligence Underwriting Company
Code Structural unit a. AIUC-1 requirements for agent data, privacy, security, safety, reliability, accountability, and societal risk. b. Evidence templates for technical implementation, legal policy, operational practice, and third-party evaluation. c. Crosswalks to AI regulations, standards, and security frameworks. d. Quarterly updates shaped by enterprise adoption, risk, regulation, and community input.
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