If you’re running agentic AI in production, you likely possess more ISO/IEC 42001 evidence than you think. ISO/IEC 42001:2023 is the first global AI management system standard, and it expects a repeatable way to govern AI—not magic paperwork you create the week before an audit. (ISO)

At ABV, we build tooling that turns the artifacts your teams already produce—agent traces, prompts, evals, incidents—into auditable evidence you can show to a 42001 assessor.

What 42001 actually asks for

42001 establishes an AI Management System (AIMS). It follows the familiar ISO management-system arc: context (Clause 4), leadership (5), planning (6), support (7), operation (8), performance evaluation (9), and improvement (10). Annexes outline objectives like accountability, fairness, privacy, and robustness, then provide implementation guidance.

The standard aligns well with public frameworks you might already use. NIST published a crosswalk mapping AI RMF practices to ISO/IEC 42001 requirements, including oversight and documentation expectations. (NIST AI Resource Center) Cloud Security Alliance released an AI Controls Matrix–to–ISO 42001 mapping on August 20, 2025, to help integrate AI controls with existing ISMS programs. If you operate in or sell to the EU, remember the Artificial Intelligence Act was published in the Official Journal on July 12, 2024, with obligations phasing in through 2025–2026.

The evidence you probably already have

Here’s the short version: much of 42001 is satisfied by disciplined software practice and security governance you already run for ISO 27001 or SOC 2.

A-LIGN’s comparison notes the overlap in governance scaffolding; 42001 primarily extends it with AI-specific policy, risk, and lifecycle controls:

  • Prompt and config version history for agents. Clause 6.3 expects change management; your Git history, PR templates, and prompt/version management already cover this. ABV tracks prompt versions and agent graphs out of the box.
  • Agent run logs that show decisions. Clause 8 requires controlled operation; distributed traces already exist via OpenTelemetry. ABV ingests OTel spans to reconstruct step-by-step tool calls and context.
  • Risk register and AI impact notes. Clause 6.1 expects risk identification; many teams keep a Jira-based risk log or DPA/DPIA records. NIST’s crosswalk calls out governance functions for inventory and decommissioning that map cleanly to this documentation.
  • Evaluation runs and A/B tests. Clause 9 asks for performance evaluation; your offline eval notebooks and experiment dashboards count, especially when tied to acceptance thresholds. ABV’s governance dashboards and experiments centralize these. (ABV)
  • Guardrails and policy checks. Clause 7.5 requires documented information; guardrails are policy-in-code that you can reference. McKinsey’s explainer frames guardrails as organizational policy enforcement—exactly what auditors look for. ABV ships validators and PromptScan. (McKinsey & Company)
  • Access control, SSO, RBAC, and audit logs. Clause 7 expects resourcing and competence; your IdP policies and application audit trails already evidence least privilege. ABV supports SSO/RBAC and organization-level audit logs.
  • Vendor and model governance. Clause 8 and Annex D anticipate third‑party relationships. Contract exhibits, model cards, and provider change notices form the packet; the EU AI Act also expects transparency from GPAI providers, including training‑data summaries. (AP News)
  • Security testing and red‑teaming. Jailbreak and prompt‑injection tests are legitimate evaluation artifacts for Clause 8 and 9. Public testing has repeatedly shown why: the UK AI Safety Institute and independent researchers have documented bypasses in mainstream and emerging models. Preserve those test logs. (The Guardian)

What’s missing for agents

Agents introduce autonomy and tools. That’s where the real gaps tend to live.

First, you need an explicit tool‑permission register per agent. List the tools, the least‑privilege scopes, allowed parameter ranges, and secrets handling strategy. Make it part of your AIMS scope statement and change control so reviewers can see that the agent could not exfiltrate keys or call bookkeeping APIs without a policy exception. 42001’s Clause 4 (scope) and 6.3 (change management) give you the hooks.

Second, step‑level explainability. A 42001 assessor won’t accept a single flat log line; they will want to understand which inputs, tools, and retrieval contexts produced a given outcome. OpenTelemetry traces provide that lineage; ABV turns those spans into agent graphs you can replay with timestamps and user or session context.

Third, human‑on‑the‑loop triggers. The NIST‑to‑42001 crosswalk calls out defined human‑oversight processes; put those thresholds and escalation paths in writing, and keep evidence that they fired during real runs. ABV’s annotation queues and guardrails generate that record automatically.

Fourth, outcome‑linked evaluation. Clause 9 expects systematic performance evaluation. For agents, that’s not only BLEU or accuracy—it’s task success rate under tool constraints, false‑positive guardrail blocks, and cost/latency budgets. ABV governance dashboards tie eval metrics to model/router versions and prompt hashes so you can show a reviewer which change moved your acceptance rate.

Finally, provenance and policy obligations from your model providers. The EU AI Act requires GPAI providers to publish training‑data summaries and to meet transparency obligations; your AIMS should reference where you store those notices and how you respond to upstream changes.

How ABV helps teams pass the sniff test

ABV emphasizes three implementation realities that match assessor expectations.

We record agent behavior the way ops teams already work: via OpenTelemetry traces, structured logs, and cost/token telemetry. That makes Clause 8 operations and Clause 9 evaluations reviewable without inventing a new evidence vocabulary.

We map features to governance. Prompt and version management, a model/router registry, guardrails, and human‑in‑the‑loop queues generate the artifacts behind Clauses 6–7 (planning/support) and 10 (improvement). Our governance dashboards help non‑engineers—product, compliance, risk—review what changed and why.

We package it. The Enterprise plan includes compliance automation for ISO 42001 alongside ISO 27001, HIPAA, and GDPR, with SSO, RBAC, and audit logs to make access and change reviews fast.

Why this also matters for EU AI Act timelines

42001 won’t make you automatically compliant with the EU AI Act, but it puts scaffolding in place for risk, oversight, record‑keeping, and post‑market monitoring. The Commission’s enforcement milestones begin to bite through 2025, with full enforcement in August 2026, so building your AIMS now reduces scramble later. CSA’s August 2025 mapping and the Official Journal publication from July 2024 provide the canonical references auditors will ask about.

What to do next with ABV

Instrument your agents with OpenTelemetry, enable ABV’s agent traces and guardrails, and write down your tool‑permission register and oversight triggers. Link your existing evals to governance dashboards and start capturing incident and change reviews in one place. When the assessor asks “show me,” you’ll already have the run, the decision trail, the policy, and the owner—organized, time‑stamped, and mapped to a clause.