AIUC-1 × SOC 2: reverse mapping

See the mapping of SOC 2 criteria by AIUC-1 requirements here.

Risk Area	AIUC-1 Requirement	Description	SOC 2 criteria
Data & Privacy	A001: Establish input data policy	Establish and communicate AI input data policies covering how customer data is used for model training, inference processing, data retention periods, and customer data rights.	C1.1: Identify and maintain confidential information — The entity identifies and maintains confidential information to meet the entity’s objectives related to confidentiality. C1.2: Dispose of confidential information — The entity disposes of confidential information to meet the entity’s objectives related to confidentiality. CC5.3: Deploy controls through policies — COSO Principle 12: The entity deploys control activities through policies that establish what is expected and in procedures that put policies into action. P1.1: Privacy notice to data subjects — The entity provides notice to data subjects about its privacy practices to meet the entity’s objectives related to privacy. The notice is updated and communicated to data subjects in a timely manner for changes to the entity’s privacy practices, including changes in the use of personal information, to meet the entity’s objectives related to privacy. P2.1: Choice and consent — The entity communicates choices available regarding the collection, use, retention, disclosure, and disposal of personal information to the data subjects and the consequences, if any, of each choice. Explicit consent for the collection, use, retention, disclosure, and disposal of personal information is obtained from data subjects or other authorized persons, if required. Such consent is obtained only for the intended purpose of the information to meet the entity’s objectives related to privacy. The entity’s basis for determining implicit consent for the collection, use, retention, disclosure, and disposal of personal information is documented. P3.1: Consistent collection of personal information — Personal information is collected consistent with the entity’s objectives related to privacy. P3.2: Explicit consent before collection — For information requiring explicit consent, the entity communicates the need for such consent as well as the consequences of a failure to provide consent for the request for personal information and obtains the consent prior to the collection of the information to meet the entity’s objectives related to privacy. P4.1: Limit use of personal information — The entity limits the use of personal information to the purposes identified in the entity’s objectives related to privacy. P4.2: Retention of personal information — The entity retains personal information consistent with the entity’s objectives related to privacy. P5.1: Data subject access rights — The entity grants identified and authenticated data subjects the ability to access their stored personal information for review and, upon request, provides physical or electronic copies of that information to data subjects to meet the entity’s objectives related to privacy. If access is denied, data subjects are informed of the denial and reason for such denial, as required, to meet the entity’s objectives related to privacy. P6.1: Disclosure with consent — The entity discloses personal information to third parties with the explicit consent of data subjects and such consent is obtained prior to disclosure to meet the entity’s objectives related to privacy. PI1.2: Input completeness and accuracy — The entity implements policies and procedures over system inputs, including controls over completeness and accuracy, to result in products, services, and reporting to meet the entity’s objectives. PI1.5: Storage completeness and accuracy — The entity implements policies and procedures to store inputs, items in processing, and outputs completely, accurately, and timely in accordance with system specifications to meet the entity’s objectives.
Data & Privacy	A002: Establish output data policy	Establish AI output ownership, usage, opt-in/out and deletion policies to customers and communicate these policies.	C1.2: Dispose of confidential information — The entity disposes of confidential information to meet the entity’s objectives related to confidentiality. CC5.3: Deploy controls through policies — COSO Principle 12: The entity deploys control activities through policies that establish what is expected and in procedures that put policies into action. P1.1: Privacy notice to data subjects — The entity provides notice to data subjects about its privacy practices to meet the entity’s objectives related to privacy. The notice is updated and communicated to data subjects in a timely manner for changes to the entity’s privacy practices, including changes in the use of personal information, to meet the entity’s objectives related to privacy. P2.1: Choice and consent — The entity communicates choices available regarding the collection, use, retention, disclosure, and disposal of personal information to the data subjects and the consequences, if any, of each choice. Explicit consent for the collection, use, retention, disclosure, and disposal of personal information is obtained from data subjects or other authorized persons, if required. Such consent is obtained only for the intended purpose of the information to meet the entity’s objectives related to privacy. The entity’s basis for determining implicit consent for the collection, use, retention, disclosure, and disposal of personal information is documented. P3.1: Consistent collection of personal information — Personal information is collected consistent with the entity’s objectives related to privacy. P3.2: Explicit consent before collection — For information requiring explicit consent, the entity communicates the need for such consent as well as the consequences of a failure to provide consent for the request for personal information and obtains the consent prior to the collection of the information to meet the entity’s objectives related to privacy. P6.1: Disclosure with consent — The entity discloses personal information to third parties with the explicit consent of data subjects and such consent is obtained prior to disclosure to meet the entity’s objectives related to privacy. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives. PI1.5: Storage completeness and accuracy — The entity implements policies and procedures to store inputs, items in processing, and outputs completely, accurately, and timely in accordance with system specifications to meet the entity’s objectives.
Data & Privacy	A003: Limit AI agent data access	Implement safeguards to limit AI agent data access based on task, user role, agent role and context.	CC6.1: Logical access security — The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events to meet the entity’s objectives. CC6.3: Role-based access management — The entity authorizes, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes, giving consideration to the concepts of least privilege and segregation of duties, to meet the entity’s objectives. P4.1: Limit use of personal information — The entity limits the use of personal information to the purposes identified in the entity’s objectives related to privacy.
Data & Privacy	A004: Protect IP & trade secrets	Implement safeguards or technical controls to prevent AI systems from leaking company intellectual property or confidential information.	C1.1: Identify and maintain confidential information — The entity identifies and maintains confidential information to meet the entity’s objectives related to confidentiality. P4.1: Limit use of personal information — The entity limits the use of personal information to the purposes identified in the entity’s objectives related to privacy.
Data & Privacy	A005: Prevent cross-customer data exposure	Implement safeguards to prevent cross-customer data exposure.	—
Data & Privacy	A006: Prevent PII leakage	Establish safeguards to prevent personal data leakage through AI outputs and logs.	C1.2: Dispose of confidential information — The entity disposes of confidential information to meet the entity’s objectives related to confidentiality. P4.1: Limit use of personal information — The entity limits the use of personal information to the purposes identified in the entity’s objectives related to privacy. P4.3: Secure disposal of personal information — The entity securely disposes of personal information to meet the entity’s objectives related to privacy. PI1.5: Storage completeness and accuracy — The entity implements policies and procedures to store inputs, items in processing, and outputs completely, accurately, and timely in accordance with system specifications to meet the entity’s objectives.
Data & Privacy	A007: Prevent IP violations	Implement safeguards and technical controls to prevent AI outputs from violating copyrights, trademarks, or other third-party intellectual property rights.	CC3.1: Clear objectives for risk assessment — COSO Principle 6: The entity specifies objectives with sufficient clarity to enable the identification and assessment of risks relating to objectives.
Data & Privacy	A008: Prevent leakage of credentials and secrets	Implement safeguards to detect and prevent leakage of secrets in AI system inputs, outputs, logs, and credential storage.	—
Data & Privacy	A009: Third-party testing for data & privacy risk	Appoint expert third-parties to evaluate system robustness to data & privacy risk as defined in the AIUC-1 risk taxonomy at least every 3 months	—
Security	B001: Third-party testing for security risk	Appoint expert third-parties to evaluate system robustness to security risk as defined in the AIUC-1 risk taxonomy at least every 3 months	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning. CC4.2: Evaluate and communicate deficiencies — COSO Principle 17: The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors, as appropriate. CC7.2: Anomaly monitoring — The entity monitors system components and the operation of those components for anomalies that are indicative of malicious acts, natural disasters, and errors affecting the entity’s ability to meet its objectives; anomalies are analyzed to determine whether they represent security events.
Security	B002: Detect adversarial input	Implement monitoring capabilities to detect and enable responding to adversarial inputs and prompt injection attempts.	CC6.6: Protection against external threats — The entity implements logical access security measures to protect against threats from sources outside its system boundaries. CC6.8: Malicious software prevention — The entity implements controls to prevent or detect and act upon the introduction of unauthorized or malicious software to meet the entity’s objectives. CC7.2: Anomaly monitoring — The entity monitors system components and the operation of those components for anomalies that are indicative of malicious acts, natural disasters, and errors affecting the entity’s ability to meet its objectives; anomalies are analyzed to determine whether they represent security events.
Security	B003: Manage public release of technical details	Implement controls to prevent over-disclosure of technical information about AI systems and organizational details that could enable adversarial targeting.	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC6.6: Protection against external threats — The entity implements logical access security measures to protect against threats from sources outside its system boundaries.
Security	B004: Prevent AI endpoint scraping	Implement safeguards to prevent probing or scraping of external AI endpoints.	CC6.6: Protection against external threats — The entity implements logical access security measures to protect against threats from sources outside its system boundaries.
Security	B005: Implement real-time input filtering	Implement real-time input filtering using automated moderation tools.	CC8.1: Change management — The entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives. PI1.2: Input completeness and accuracy — The entity implements policies and procedures over system inputs, including controls over completeness and accuracy, to result in products, services, and reporting to meet the entity’s objectives.
Security	B006: Prevent unauthorized AI agent actions	Implement safeguards to prevent AI agents from performing actions beyond intended scope and authorized privileges.	CC5.1: Select and develop control activities — COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. CC6.3: Role-based access management — The entity authorizes, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes, giving consideration to the concepts of least privilege and segregation of duties, to meet the entity’s objectives.
Security	B007: Enforce user access privileges to AI systems	Establish and maintain user access controls and admin privileges for AI systems in line with policy.	CC5.2: General controls over technology — COSO Principle 11: The entity also selects and develops general control activities over technology to support the achievement of objectives. CC6.1: Logical access security — The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events to meet the entity’s objectives. CC6.2: User registration and deprovisioning — Prior to issuing system credentials and granting system access, the entity registers and authorizes new internal and external users whose access is administered by the entity. For those users whose access is administered by the entity, user system credentials are removed when user access is no longer authorized. CC6.3: Role-based access management — The entity authorizes, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes, giving consideration to the concepts of least privilege and segregation of duties, to meet the entity’s objectives.
Security	B008: Protect AI system deployment environment	Implement security measures for AI system deployment environments including encryption, access controls and authorization.	CC5.2: General controls over technology — COSO Principle 11: The entity also selects and develops general control activities over technology to support the achievement of objectives. CC6.1: Logical access security — The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events to meet the entity’s objectives. CC6.6: Protection against external threats — The entity implements logical access security measures to protect against threats from sources outside its system boundaries. CC6.7: Secure transmission and removal — The entity restricts the transmission, movement, and removal of information to authorized internal and external users and processes, and protects it during transmission, movement, or removal to meet the entity’s objectives. CC6.8: Malicious software prevention — The entity implements controls to prevent or detect and act upon the introduction of unauthorized or malicious software to meet the entity’s objectives.
Security	B009: Limit output over-exposure	Implement output limitations and obfuscation techniques to safeguard against information leakage.	CC8.1: Change management — The entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Security	B010: Promote secure patterns in generated code	Implement safeguards to promote secure patterns and prevent known vulnerabilities in generated code.	CC5.2: General controls over technology — COSO Principle 11: The entity also selects and develops general control activities over technology to support the achievement of objectives. CC6.8: Malicious software prevention — The entity implements controls to prevent or detect and act upon the introduction of unauthorized or malicious software to meet the entity’s objectives. CC7.1: Vulnerability detection and monitoring — To meet its objectives, the entity uses detection and monitoring procedures to identify (1) changes to configurations that result in the introduction of new vulnerabilities, and (2) susceptibilities to newly discovered vulnerabilities.
Safety	C001: Define AI risk taxonomy	Establish a risk taxonomy based on system capabilities and deployment context.	CC3.1: Clear objectives for risk assessment — COSO Principle 6: The entity specifies objectives with sufficient clarity to enable the identification and assessment of risks relating to objectives. CC3.2: Identify and analyze risks — COSO Principle 7: The entity identifies risks to the achievement of its objectives across the entity and analyzes risks as a basis for determining how the risks should be managed. CC5.1: Select and develop control activities — COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels.
Safety	C002: Conduct pre-deployment testing	Conduct internal testing of AI systems prior to deployment across risk categories for system changes requiring formal review or approval.	CC3.2: Identify and analyze risks — COSO Principle 7: The entity identifies risks to the achievement of its objectives across the entity and analyzes risks as a basis for determining how the risks should be managed. CC8.1: Change management — The entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives.
Safety	C003: Prevent harmful outputs	Implement safeguards or technical controls to prevent harmful outputs including distressed outputs, angry responses, high-risk advice, offensive content, bias, and deception.	CC5.1: Select and develop control activities — COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Safety	C004: Prevent out-of-scope outputs	Implement safeguards or technical controls to prevent out-of-scope outputs (e.g. political discussion, healthcare advice).	CC5.1: Select and develop control activities — COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Safety	C005: Prevent agent-specific high risk outputs	Implement safeguards or technical controls to prevent agent-specific high-risk outputs as defined in risk taxonomy.	CC3.2: Identify and analyze risks — COSO Principle 7: The entity identifies risks to the achievement of its objectives across the entity and analyzes risks as a basis for determining how the risks should be managed. CC5.1: Select and develop control activities — COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Safety	C006: Prevent output vulnerabilities	Implement safeguards to prevent security vulnerabilities in outputs from impacting users.	CC6.8: Malicious software prevention — The entity implements controls to prevent or detect and act upon the introduction of unauthorized or malicious software to meet the entity’s objectives. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Safety	C007: Flag high risk outputs for human review	Implement an alerting system that flags high-risk outputs for human review.	PI1.3: Processing controls — The entity implements policies and procedures over system processing to result in products, services, and reporting to meet the entity’s objectives.
Safety	C008: Monitor AI risk categories	Implement monitoring of AI systems across risk categories.	CC2.1: Use of relevant, quality information — COSO Principle 13: The entity obtains or generates and uses relevant, quality information to support the functioning of internal control. CC3.2: Identify and analyze risks — COSO Principle 7: The entity identifies risks to the achievement of its objectives across the entity and analyzes risks as a basis for determining how the risks should be managed. CC7.2: Anomaly monitoring — The entity monitors system components and the operation of those components for anomalies that are indicative of malicious acts, natural disasters, and errors affecting the entity’s ability to meet its objectives; anomalies are analyzed to determine whether they represent security events. CC7.3: Security event evaluation — The entity evaluates security events to determine whether they could or have resulted in a failure of the entity to meet its objectives (security incidents) and, if so, takes actions to prevent or address such failures.
Safety	C009: Enable real-time feedback and intervention	Implement mechanisms to enable real-time user feedback collection, intervention and actioning mechanisms.	PI1.1: Relevant processing information — The entity obtains or generates, uses, and communicates relevant, quality information regarding the objectives related to processing, including definitions of data processed and product and service specifications, to support the use of products and services. PI1.3: Processing controls — The entity implements policies and procedures over system processing to result in products, services, and reporting to meet the entity’s objectives.
Safety	C010: Third-party testing for safety risk	Appoint expert third-parties to evaluate system robustness to safety risk as defined in the AIUC-1 risk taxonomy at least every 3 months	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.
Safety	C011: [Retired] Third-party testing for out-of-scope outputs	Retired - see changelog (Q4 2026 update).	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.
Safety	C012: [Retired] Third-party testing for customer-defined risk	Retired - see changelog (Q4 2026 update).	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.
Reliability	D001: Prevent hallucinated outputs	Implement safeguards or technical controls to prevent hallucinated outputs.	PI1.2: Input completeness and accuracy — The entity implements policies and procedures over system inputs, including controls over completeness and accuracy, to result in products, services, and reporting to meet the entity’s objectives. PI1.3: Processing controls — The entity implements policies and procedures over system processing to result in products, services, and reporting to meet the entity’s objectives. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Reliability	D002: [Retired] Third-party testing for hallucinations	Retired - see changelog (Q4 2026 update).	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning. PI1.3: Processing controls — The entity implements policies and procedures over system processing to result in products, services, and reporting to meet the entity’s objectives. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Reliability	D003: Restrict unsafe tool calls	Implement safeguards or technical controls to prevent tool calls in AI systems from executing unauthorized actions, accessing restricted information, or making decisions beyond their intended scope.	CC5.1: Select and develop control activities — COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. PI1.2: Input completeness and accuracy — The entity implements policies and procedures over system inputs, including controls over completeness and accuracy, to result in products, services, and reporting to meet the entity’s objectives. PI1.3: Processing controls — The entity implements policies and procedures over system processing to result in products, services, and reporting to meet the entity’s objectives. PI1.4: Output delivery accuracy — The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.
Reliability	D004: Third-party testing for reliability risk	Appoint expert third-parties to evaluate system robustness to reliability risk as defined in the AIUC-1 risk taxonomy at least every 3 months	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.
Accountability	E001: AI failure plan for security breaches	Document AI failure plan for AI privacy and security breaches assigning accountable owners and establishing notification and remediation with third-party support as needed (e.g. legal, PR, insurers).	CC4.2: Evaluate and communicate deficiencies — COSO Principle 17: The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors, as appropriate. CC7.3: Security event evaluation — The entity evaluates security events to determine whether they could or have resulted in a failure of the entity to meet its objectives (security incidents) and, if so, takes actions to prevent or address such failures. CC7.4: Incident response — The entity responds to identified security incidents by executing a defined incident-response program to understand, contain, remediate, and communicate security incidents, as appropriate. CC7.5: Recovery from incidents — The entity identifies, develops, and implements activities to recover from identified security incidents. P6.3: Record of unauthorized disclosures — The entity creates and retains a complete, accurate, and timely record of detected or reported unauthorized disclosures (including breaches) of personal information to meet the entity’s objectives related to privacy. P6.5: Vendor breach notification commitments — The entity obtains commitments from vendors and other third parties with access to personal information to notify the entity in the event of actual or suspected unauthorized disclosures of personal information. Such notifications are reported to appropriate personnel and acted on in accordance with established incident-response procedures to meet the entity’s objectives related to privacy. P6.6: Breach notification obligations — The entity provides notification of breaches and incidents to affected data subjects, regulators, and others to meet the entity’s objectives related to privacy.
Accountability	E002: AI failure plan for harmful outputs	Document AI failure plan for harmful AI outputs that cause significant customer harm assigning accountable owners and establishing remediation with third-party support as needed (e.g. legal, PR, insurers).	CC4.2: Evaluate and communicate deficiencies — COSO Principle 17: The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors, as appropriate. CC7.4: Incident response — The entity responds to identified security incidents by executing a defined incident-response program to understand, contain, remediate, and communicate security incidents, as appropriate.
Accountability	E003: AI failure plan for hallucinations	Document AI failure plan for hallucinated AI outputs that cause substantial customer financial loss assigning accountable owners and establishing remediation with third-party support as needed (e.g. legal, PR, insurers).	CC4.2: Evaluate and communicate deficiencies — COSO Principle 17: The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors, as appropriate. CC7.4: Incident response — The entity responds to identified security incidents by executing a defined incident-response program to understand, contain, remediate, and communicate security incidents, as appropriate.
Accountability	E004: Assign accountability	Document which AI system changes across the development & deployment lifecycle require formal review or approval, assign a lead accountable for each, and document their approval with supporting evidence.	CC1.3: Structures, authorities, and responsibilities — COSO Principle 3: Management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the pursuit of objectives. CC1.5: Accountability for internal control — COSO Principle 5: The entity holds individuals accountable for their internal control responsibilities in the pursuit of objectives. CC5.3: Deploy controls through policies — COSO Principle 12: The entity deploys control activities through policies that establish what is expected and in procedures that put policies into action. CC8.1: Change management — The entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives.
Accountability	E005: Document data storage security	Document data storage security practices considering data sensitivity, regulatory requirements, security controls, and operational needs.	C1.1: Identify and maintain confidential information — The entity identifies and maintains confidential information to meet the entity’s objectives related to confidentiality. CC6.1: Logical access security — The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events to meet the entity’s objectives.
Accountability	E006: Conduct vendor and model due diligence	Establish due diligence processes for foundation and upstream model providers covering data handling, PII controls, security and compliance.	CC9.2: Vendor and partner risk — The entity assesses and manages risks associated with vendors and business partners. P6.4: Vendor privacy commitments — The entity obtains privacy commitments from vendors and other third parties who have access to personal information to meet the entity’s objectives related to privacy. The entity assesses those parties’ compliance on a periodic and as-needed basis and takes corrective action, if necessary. P6.5: Vendor breach notification commitments — The entity obtains commitments from vendors and other third parties with access to personal information to notify the entity in the event of actual or suspected unauthorized disclosures of personal information. Such notifications are reported to appropriate personnel and acted on in accordance with established incident-response procedures to meet the entity’s objectives related to privacy.
Accountability	E007: [Retired] Document system change approvals	Merged with E004 - see changelog (Q1 2026 update).	—
Accountability	E008: Review internal processes	Establish regular internal reviews of key processes and document review records and approvals.	CC1.3: Structures, authorities, and responsibilities — COSO Principle 3: Management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the pursuit of objectives. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning. CC4.2: Evaluate and communicate deficiencies — COSO Principle 17: The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors, as appropriate. CC5.3: Deploy controls through policies — COSO Principle 12: The entity deploys control activities through policies that establish what is expected and in procedures that put policies into action. CC8.1: Change management — The entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives.
Accountability	E009: Monitor third-party access	Implement systems to monitor and log third-party API connections, sessions, and data access.	CC6.2: User registration and deprovisioning — Prior to issuing system credentials and granting system access, the entity registers and authorizes new internal and external users whose access is administered by the entity. For those users whose access is administered by the entity, user system credentials are removed when user access is no longer authorized. CC7.1: Vulnerability detection and monitoring — To meet its objectives, the entity uses detection and monitoring procedures to identify (1) changes to configurations that result in the introduction of new vulnerabilities, and (2) susceptibilities to newly discovered vulnerabilities. CC9.2: Vendor and partner risk — The entity assesses and manages risks associated with vendors and business partners.
Accountability	E010: Establish AI acceptable use policy	Establish and implement an AI acceptable use policy.	CC1.1: Commitment to integrity and ethical values — COSO Principle 1: The entity demonstrates a commitment to integrity and ethical values. CC5.3: Deploy controls through policies — COSO Principle 12: The entity deploys control activities through policies that establish what is expected and in procedures that put policies into action.
Accountability	E011: Record processing locations	Document AI data processing locations.	CC2.1: Use of relevant, quality information — COSO Principle 13: The entity obtains or generates and uses relevant, quality information to support the functioning of internal control.
Accountability	E012: Document regulatory compliance	Document applicable AI laws and standards, required data protections, and strategies for compliance.	CC3.1: Clear objectives for risk assessment — COSO Principle 6: The entity specifies objectives with sufficient clarity to enable the identification and assessment of risks relating to objectives. P6.6: Breach notification obligations — The entity provides notification of breaches and incidents to affected data subjects, regulators, and others to meet the entity’s objectives related to privacy.
Accountability	E013: Implement quality management system	Establish a quality management system for AI systems proportionate to the size of the organization.	CC1.3: Structures, authorities, and responsibilities — COSO Principle 3: Management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the pursuit of objectives. CC4.1: Ongoing and separate evaluations — COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning. CC5.3: Deploy controls through policies — COSO Principle 12: The entity deploys control activities through policies that establish what is expected and in procedures that put policies into action.
Accountability	E014: [Retired] Share transparency reports	Merged with E017 - see changelog (Q1 2026 update).	—
Accountability	E015: Log AI system activity	Maintain logs of AI system processes, actions, and agent outputs where permitted to support incident investigation, auditing, and explanation of AI system behavior.	CC2.1: Use of relevant, quality information — COSO Principle 13: The entity obtains or generates and uses relevant, quality information to support the functioning of internal control. P4.2: Retention of personal information — The entity retains personal information consistent with the entity’s objectives related to privacy. PI1.5: Storage completeness and accuracy — The entity implements policies and procedures to store inputs, items in processing, and outputs completely, accurately, and timely in accordance with system specifications to meet the entity’s objectives.
Accountability	E016: Implement AI disclosure mechanisms	Implement clear disclosure mechanisms to inform users when they are interacting with AI systems rather than humans.	CC2.2: Internal communication of controls — COSO Principle 14: The entity internally communicates information, including objectives and responsibilities for internal control, necessary to support the functioning of internal control. CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control.
Accountability	E017: Document system transparency policy	Establish a system transparency policy and maintain a repository of model cards, datasheets, and interpretability reports for major systems.	CC2.3: External communication of controls — COSO Principle 15: The entity communicates with external parties regarding matters affecting the functioning of internal control. CC6.1: Logical access security — The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events to meet the entity’s objectives.
Accountability	E018: Third-party testing for accountability risk	Appoint expert third-parties to evaluate system robustness to accountability risk as defined in the AIUC-1 risk taxonomy at least every 3 months	—
Society	F001: Prevent AI cyber misuse	Implement or document guardrails to prevent AI-enabled misuse for cyber attacks and exploitation.	CC7.3: Security event evaluation — The entity evaluates security events to determine whether they could or have resulted in a failure of the entity to meet its objectives (security incidents) and, if so, takes actions to prevent or address such failures.
Society	F002: Prevent catastrophic misuse	Implement or document guardrails to prevent AI-enabled catastrophic system misuse (chemical / bio / radio / nuclear).	—

Last updated October 15, 2026.

Introduction

Context

Standard

Certification

Evals Methodology

Auditors

Legal

AIUC-1 × SOC 2: reverse mapping