AI Governance, Risk, and Compliance · Topic 3 of 3

AI Compliance Frameworks and Corporate AI Policy

Compare the EU AI Act, OECD principles, ISO/IEC 42001 and the NIST AI RMF, and set corporate AI policy on models, sensitive data and data sovereignty.

  • 7 min
In a nutshell
  • The EU AI Act is binding law with four risk tiers and applies to anyone placing AI on the EU market.
  • The OECD AI Principles are non-binding values: growth, human rights, transparency, robustness and accountability.
  • ISO/IEC 42001 is the certifiable AI management system standard; ISO/IEC 23894 gives risk guidance.

What it is

Compliance for artificial intelligence (AI) means meeting the laws, standards and internal rules that apply to how AI is built and used. Some are binding law, some voluntary frameworks, and some certifiable standards.

Compliance shapes business decisions directly: whether a use case is allowed, which model may be used, where data may be processed and how much testing is needed.

External ruleslaw, standards, frameworksCorporate policysanctioned tools, data rulesControlstesting, documentation, oversightEvidenceaudits and records

How it works

The four external frameworks

FrameworkTypeCore idea
European Union (EU) AI ActBinding regulationObligations scale with the risk an AI system poses
Organisation for Economic Co-operation and Development (OECD) AI PrinciplesIntergovernmental, non-binding valuesHigh-level principles for trustworthy AI adopted by many countries
International Organization for Standardization (ISO) AI standardsVoluntary standards, some certifiableManagement systems, risk guidance and shared terminology
National Institute of Standards and Technology (NIST) AI Risk Management Framework (AI RMF)Voluntary United States frameworkFour functions to manage AI risk across the life cycle

EU AI Act

The EU AI Act entered into force in 2024, with obligations applying in phases. It reaches beyond Europe: it applies to providers who place AI systems on the EU market and to deployers using them in the EU, wherever those organisations are based.

Risk tierExamplesObligations
UnacceptableSocial scoring, manipulative techniques that cause significant harmProhibited
HighAI used in employment decisions, credit scoring, education, critical infrastructure, law enforcementRisk management, data governance, technical documentation, logging, human oversight, accuracy, robustness and cybersecurity, conformity assessment
Limited (transparency)Chatbots, AI-generated or manipulated content such as deepfakesTell people they are interacting with AI; label synthetic content
MinimalSpam filters, AI in video gamesNo specific obligations beyond general duties such as AI literacy

General-purpose AI models, such as large language models, carry their own duties, including technical documentation and information for downstream providers. The most serious breaches, for prohibited practices, can bring fines of up to 35 million euros or 7% of worldwide annual turnover, whichever is higher.

OECD AI Principles

The OECD principles, adopted in 2019 and updated in 2024, were the first intergovernmental standard on AI. They set five values-based principles:

  1. Inclusive growth, sustainable development and well-being.
  2. Respect for the rule of law, human rights and democratic values, including fairness and privacy.
  3. Transparency and explainability.
  4. Robustness, security and safety.
  5. Accountability.

They also make recommendations to governments, and many national laws echo them.

ISO AI standards

ISO publishes its AI standards jointly with the International Electrotechnical Commission (IEC), so they carry the ISO/IEC prefix.

StandardPurpose
ISO/IEC 42001AI management system (AIMS) requirements; an organisation can be certified against it
ISO/IEC 23894Guidance on AI risk management, building on general risk management practice
ISO/IEC 22989AI concepts and terminology

ISO/IEC 42001 works like ISO/IEC 27001 does for information security: policies, roles, risk assessment, controls and continual improvement, verified by external audit.

NIST AI RMF

The NIST AI RMF is voluntary and sector-neutral. It is organised into four functions.

FunctionWhat it does
GovernCulture, policies, roles and accountability for AI risk; applies across the other three
MapEstablish context: purpose, users, impacts and risks of each system
MeasureAssess, test and track identified risks with metrics
ManagePrioritise and act on risks: mitigate, transfer, avoid or accept

A NIST Generative AI Profile applies it to generative AI. The RMF describes trustworthy AI as valid and reliable, safe, secure and resilient, accountable and transparent, explainable and interpretable, privacy-enhanced, and fair with harmful bias managed.

Corporate policies

Policy areaWhat it decides
Sanctioned vs. unsanctionedWhich AI tools are approved; unapproved tools are blocked or monitored
Private vs. public modelsWhether data may go to a public, shared model service or must stay in a private model hosted by or for the organisation
Sensitive data governanceWhich data classifications may be used with which models, and with what safeguards
Third-party compliance evaluationsAssessing AI vendors: security evidence, certifications, data retention and use of inputs for training
Data sovereigntyData is subject to the laws of the country where it is stored or processed, so hosting regions must match legal needs

A private model gives more control over data and logs but costs more to run. A public model service is easier to adopt, but its contract must cover retention, training on inputs and location.

Third-party compliance evaluations

When an organization uses an outside AI model, API or platform, it inherits that provider's risks, so it evaluates the provider before and during use:

MethodWhat it gives
Security and AI questionnairesThe provider's own answers on data handling, model training on customer data, retention and incident response
Independent reports and certificationsEvidence from an auditor, such as a SOC 2 report or ISO/IEC 27001 and ISO/IEC 42001 certification
Contract termsBinding commitments: data use limits, data location, breach notification, audit rights and termination
Ongoing reviewRe-assessment on a schedule or when the provider changes its models or terms

A provider that will not say whether customer prompts are used to train its models fails the evaluation for sensitive data.

A worked example

A European insurer plans an AI system to help assess job applicants. Under the EU AI Act this is high risk, so the system must meet the high-risk requirements, such as risk management, data governance, documentation, logging and human oversight, before it is used. The vendor as provider and the insurer as deployer each carry their own duties.

The insurer maps and measures risks with the NIST AI RMF, runs the system inside an ISO/IEC 42001 management system, evaluates the vendor, and hosts the model in an EU region for data sovereignty.

Hiring use caseEU AI Acthigh riskNIST AI RMFmap and measureISO 42001management systemVendor evaluationEU hosting

How the exam asks about this

  • "A company wants an external certification showing it runs a formal management system for its AI. Which of the following should it pursue?" ISO/IEC 42001 certification.
  • "A risk team wants a voluntary framework organised into Govern, Map, Measure and Manage functions. Which of the following should it adopt?" The NIST AI RMF.
  • "Customer data must not be processed outside the country where it was collected. Which of the following policy considerations applies?" Data sovereignty.

What to remember for the exam

  • The EU AI Act is binding law with four risk tiers and applies to anyone placing AI on the EU market.
  • The OECD AI Principles are non-binding values: growth, human rights, transparency, robustness and accountability.
  • ISO/IEC 42001 is the certifiable AI management system standard; ISO/IEC 23894 gives risk guidance.
  • The NIST AI RMF has four functions: Govern, Map, Measure and Manage.
  • Corporate policy covers sanctioned tools, private versus public models, sensitive data, vendor evaluations and data sovereignty.
Watch out

Using a third-party AI service does not transfer your compliance duties. Under most laws the organisation that deploys the system remains responsible, so vendor evaluations and contracts are required controls.

Common mistakes

Calling the NIST AI RMF a certification. It is voluntary guidance; there is no NIST AI RMF certificate. ISO/IEC 42001 is the certifiable standard.

Assuming the EU AI Act affects only EU companies. It applies to providers placing AI on the EU market and to use within the EU, wherever the company is based.

Treating every AI system as high risk. Most systems fall into the minimal or limited tiers; high-risk duties apply to listed sensitive uses.

Check yourself

  • What are the four risk tiers of the EU AI Act?

    Unacceptable (prohibited), high, limited (transparency obligations) and minimal.

  • Which NIST AI RMF function applies across all the others?

    Govern, which sets the culture, policies and accountability for managing AI risk.

  • What should a third-party compliance evaluation of an AI vendor check?

    Its security evidence and certifications, how long it keeps data, where data is processed and whether inputs are used to train its models.

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