Author: Derrick D. Jackson
Title: Founder & Senior Director of Cloud Security Architecture & Risk
Credentials: CISSP, CRISC, CCSP
Last updated: 11/26/2025
Table of Contents
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ISO 42001 Documentation Requirements
ISO 42001 requires ~20 specific documents plus whatever else your organization needs to make the system work. That sounds overwhelming until you realize there’s a logical sequence to building these documents. Some create the foundation. Others can’t exist until that foundation is in place.
The standard published in December 2023 follows the same structure as ISO 27001, which means organizations already familiar with information security management systems will recognize the pattern. You need policies before you can write procedures. You need risk assessments before you can determine controls. The trick is knowing where to start.
Disclaimer: This guide references ISO/IEC 42001:2023 for educational purposes. It provides implementation guidance and identifies required documentation but does not reproduce the standard’s normative content. Organizations implementing an AI management system should obtain the official ISO/IEC 42001:2023 standard from ISO (www.iso.org) or authorized distributors for complete requirements, detailed specifications, and implementation guidance.
How Documentation Flows Through the System
Your AIMS documentation splits into two categories. First: the operational documents that tell people what to do (policies, procedures, process definitions). Second: the evidence records that prove you actually did it (audit results, risk assessment outcomes, corrective action logs).
Both matter for compliance. But you can’t generate records until the processes exist.
The table below maps every required document to its place in your governance structure, shows which Annex A controls depend on it, and explains the implementation sequence. Start at Priority 1. Work down. Each tier builds on what came before.
Implementation Priority Guide
Priority 1 (Foundation): These documents define your playing field. Without them, you’re building on sand. You need to know what’s in scope before you can assess risks. You need a policy before you can set objectives. Complete these first.
Priority 2 (Risk Framework): Once you know what you’re governing, you need to understand what could go wrong and how bad it could be. These documents create your risk management engine. Everything else flows from risk decisions.
Priority 3 (Operational): Now you’ve got direction and you understand your risks. Time to document how work actually gets done. These procedures turn strategy into action.
Priority 4 (Evidence): As operations run, you generate proof. These records demonstrate your system works. They’re continuous rather than one-time documents.
Priority 5 (Improvement): Your system is running and you’re collecting evidence. These documents capture how you fix problems and get better over time.
ISO 42001 Documentation Map
| Document Required | Why It Exists | Related Annex A Controls | Implementation Priority | Dependencies & What It Enables |
| AIMS Scope (Clause 4.3) | Defines boundaries of your AI management system so everyone knows what’s covered and what isn’t | A.2.2 AI Policy | Priority 1 | No dependencies. First document to create. Enables: all other documentation by defining what falls under governance |
| AI Policy (Clause 5.2) | Provides management direction for all AI activities, establishes organizational commitment | A.2.2 AI Policy, A.2.3 Alignment with other policies, A.2.4 Review of AI policy | Priority 1 | Depends on: AIMS Scope. Enables: setting AI objectives, establishing risk criteria, all downstream processes |
| Roles, Responsibilities & Authorities (Clause 5.3) | Defines who is accountable for what within the AIMS | A.3.2 AI roles and responsibilities, A.3.3 Reporting AI system concerns | Priority 1 | Depends on: AIMS Scope, AI Policy. Enables: accountability structure, competence planning, audit trails |
| AI Objectives (Clause 6.2) | Translates policy into measurable targets so you can track progress | A.6.1 Objectives of the AI system life cycle, A.9.3 Objectives for continual improvement | Priority 1 | Depends on: AI Policy. Enables: planning activities, resource allocation, performance measurement |
| AI Risk Criteria (Clause 6.1.1) | Sets thresholds for acceptable vs. unacceptable risk so decisions are consistent | A.8.3 AI system risk assessment throughout the AI system life cycle | Priority 2 | Depends on: AI Policy, AIMS Scope. Enables: risk assessments, risk treatment decisions |
| AI Risk Assessment Process (Clause 6.1.2) | Defines how you identify and evaluate AI risks in a repeatable way | A.8.3 AI system risk assessment throughout the AI system life cycle, A.8.5 Regular review of risks | Priority 2 | Depends on: AI Risk Criteria. Enables: conducting actual risk assessments, comparing results across systems |
| AI Risk Treatment Process (Clause 6.1.3) | Explains how you respond to identified risks and select controls | A.8.4 AI system risk treatment | Priority 2 | Depends on: AI Risk Assessment Process. Enables: creating risk treatment plans, determining necessary controls |
| AI Risk Treatment Plan (Clause 6.1.3) | Documents specific actions to address each identified risk | A.8.4 AI system risk treatment | Priority 2 | Depends on: AI Risk Treatment Process, results of risk assessments. Enables: implementing controls, tracking treatment effectiveness |
| Necessary Controls (Clause 6.1.3) | Lists specific measures you’re implementing to treat risks | All Annex A controls as applicable | Priority 2 | Depends on: AI Risk Treatment Plan. Enables: operational procedures, Statement of Applicability |
| Statement of Applicability (SoA) (Clause 6.1.3) | Justifies why each Annex A control is included or excluded from your system | All Annex A controls | Priority 2 | Depends on: Necessary Controls, comparison with all Annex A controls. Enables: audit planning, gap analysis |
| AIIA Process (Clause 6.1.4) | Defines how you assess impacts on individuals and society | A.5.2 AI system impact assessment process, A.5.3 Documentation of AI system impact assessment, A.5.4 Assessing AI system impact on individuals and groups, A.5.5 Assessing societal impacts | Priority 2 | Depends on: AI Policy, AIMS Scope. Enables: conducting impact assessments, informing risk assessments |
| Resource Documentation (Clause 7.1) | Catalogs data, tools, compute, and people needed for AI systems | A.4.2 Resource documentation, A.4.3 Data resources, A.4.4 Tooling resources, A.4.5 System and computing resources, A.4.6 Human resources | Priority 3 | Depends on: AIMS Scope, AI Objectives. Enables: capacity planning, dependency mapping, impact assessments |
| Operational Planning & Control Documentation (Clause 8.1) | Proves processes ran as intended, not just as documented | A.7.1 Operational planning and control, A.7.2 AI system requirements, A.7.3 Data governance | Priority 3 | Depends on: All process documents (risk, AIIA, etc.). Enables: demonstrating control effectiveness |
| Actions to Address Risks/Opportunities (Clause 6.1.1 record) | Tracks what you decided to do about each risk | A.8.4 AI system risk treatment | Priority 4 | Depends on: Risk Treatment Process running. Enables: accountability, effectiveness evaluation |
| Risk Assessment Results (Clause 8.2 record) | Captures findings from each risk assessment cycle | A.8.3 AI system risk assessment throughout the AI system life cycle | Priority 4 | Depends on: Risk Assessment Process running. Enables: trending, comparison, treatment decisions |
| Risk Treatment Results (Clause 8.3 record) | Documents outcomes of risk treatment actions | A.8.4 AI system risk treatment | Priority 4 | Depends on: Risk Treatment Plan execution. Enables: proving controls work, identifying gaps |
| AIIA Results (Clause 6.1.4, 8.4 record) | Records determined impacts on people and society | A.5.3 Documentation of AI system impact assessment, A.5.4 Assessing AI system impact on individuals and groups, A.5.5 Assessing societal impacts | Priority 4 | Depends on: AIIA Process running. Enables: feeding risk assessments, stakeholder communication |
| Competence Evidence (Clause 7.2 record) | Proves people have the skills for their AI roles | A.4.6 Human resources | Priority 3 | Depends on: Resource Documentation identifying roles. Enables: role assignments, training plans |
| Monitoring & Measurement Results (Clause 9.1 record) | Shows how well the AIMS is performing against objectives | A.9.2 Measuring AI system performance, A.9.3 Objectives for continual improvement | Priority 4 | Depends on: AI Objectives, operational processes running. Enables: management decisions, improvement actions |
| Internal Audit Programme & Results (Clause 9.2.2) | Demonstrates independent review of AIMS conformance | A.2.4 Review of AI policy (audit informs reviews) | Priority 4 | Depends on: All other documents existing. Enables: identifying nonconformities, improvement opportunities |
| Management Review Results (Clause 9.3.3 record) | Documents leadership decisions about AIMS effectiveness | A.2.4 Review of AI policy | Priority 4 | Depends on: Audit results, monitoring results, operational data. Enables: strategic changes, resource decisions |
| Nonconformity & Corrective Action (Clause 10.2 record) | Tracks problems found and fixes implemented | A.9.4 Logging | Priority 5 | Depends on: Operating system detecting issues. Enables: preventing recurrence, demonstrating improvement |
Key Annex A Control Categories (Reference Only)
The table references these control groups from Annex A. Each control has detailed implementation guidance in Annex B of ISO 42001:2023.
A.2: Policies related to AI (controls 2.2, 2.3, 2.4)
A.3: Internal organization (controls 3.2, 3.3)
A.4: Resources for AI systems (controls 4.2, 4.3, 4.4, 4.5, 4.6)
A.5: AI system impact assessment (controls 5.2, 5.3, 5.4, 5.5)
A.6: Objectives (control 6.1)
A.7: Operational planning (controls 7.1, 7.2, 7.3)
A.8: AI system risk management (controls 8.3, 8.4, 8.5)
A.9: Performance and improvement (controls 9.2, 9.3, 9.4)
Additional control categories exist in Annex A covering data quality, AI model, testing, transparency, human oversight, and other domains. Your Statement of Applicability determines which controls apply to your organization.
Starting Your Implementation
Three documents unlock everything else: AIMS Scope, AI Policy, and AI Objectives. Get those right and the rest follows a logical path.
Your scope document answers: what AI systems, what organizational boundaries, what activities fall under this management system? Be specific. Vague scopes create confusion when determining if a control applies.
Once scope is clear, your policy sets direction. This isn’t a compliance checkbox. Your policy should reflect actual organizational values and risk appetite. If you don’t mean it, people will ignore it.
Objectives turn policy into targets. “Reduce bias in hiring AI” beats “improve fairness” because you can measure it. If you can’t tell whether you achieved an objective, you wrote it wrong.
After that foundation, you build your risk engine (Priority 2). Then operational procedures (Priority 3). Then you run the system and collect evidence (Priority 4). Finally, you fix problems and improve (Priority 5).
The documents aren’t the goal. They’re tools to manage AI responsibly. Start simple, prove it works, then expand. A basic AIMS you actually use beats a comprehensive one that sits on a shelf.
View our ISO 42001 Resource Hub for more ISO 42001 Information.
View our ISO 42001 Template Documentation to Accelerate your program.
Portions of this guide reference ISO/IEC 42001:2023 Information Technology — Artificial Intelligence — Management System — Requirements.
© ISO 2023 — All rights reserved.
ISO/IEC 42001 control numbers and clause identifiers are used for alignment and traceability only. The interpretations, summaries, and guidance in this publication are original works of Tech Jacks Solutions LLC and do not reproduce ISO’s copyrighted material.
The official ISO/IEC 42001 standard is available for purchase at www.iso.org.
