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AI governance with ISO/IEC 42001: a checklist for the project lead

Governance3 min readYunus Sevğane

ISO/IEC 42001:2023 is a management system standard for artificial intelligence: it does not describe a single model or product but how an organization manages AI. I completed lead auditor training for this standard in 2025. This post is not a certification claim and not a substitute for the standard; it is a question list, distilled from that training and my project management experience, that makes a project lead’s job easier.

First, a distinction: an organization’s certificate versus a working method

ISO/IEC 42001 is a management system standard that organizations can be certified against. I do not hold an organizational certificate; I use the perspective I gained from lead auditor training as a working method at project level. So the list below is the question list of a project lead who says “governance should not be added afterwards”. If your goal is organizational certification, this list is only a good starting point, not a replacement.

1. Purpose and scope

  • Which business question or process does the AI system serve?
  • Who will use it, in what context, and in which situations must it not be used?
  • Are the out-of-scope items written down?

2. Responsibility and roles

  • Who is the business owner of the system, and who is the technical owner?
  • Whom does one go to when an output is challenged or an error is noticed?
  • Who holds the decision rights to expand, stop or roll back?

3. Data

  • Where does the data come from, and do we have the right and permission to use it?
  • Does it contain personal data and, if so, which rules and safeguards apply?
  • Who can access which data, and what are the retention and deletion rules?
  • Who monitors data quality and freshness, and how?

4. Risk and impact assessment

  • If the system misbehaves, who is affected and how?
  • Are risks kept in a register with an owner and a mitigation each?
  • Have the points that need human approval been identified?
  • What control exists for wrong, biased or fabricated output?

5. Lifecycle and change

  • Are design, testing, deployment, maintenance and retirement defined?
  • Is there a re-assessment when the model, the prompt or the data changes?
  • Are changes recorded?

6. Third parties

  • Which external model, service or data provider is used?
  • What data goes to that provider, and do the contract and privacy terms cover it?
  • What happens if the provider changes or the service stops?

7. Monitoring and improvement

  • What do we monitor while the system is live, and how often?
  • Can users report problems, and whose desk do the reports land on?
  • How do findings turn into the next improvement decision?

How do I use this list in a project?

I use the list as part of planning, not as an audit form. In the first weeks the answers are collected; questions that cannot be answered go into the risk register with an owner and a date. After the pilot the list is reviewed again, and the decision to expand is made by looking at those answers. That way governance becomes a record that feeds decisions rather than a pile of documents added at the end of the project.

Assessing the standard itself and whether your organization needs certification is a separate job; I recommend getting support from an independent expert or an accredited certification body for that. For my own working approach, see the Information Security and ISO Compliance and AI Projects pages.