Chapter 11

Annex A Controls: Policies & Internal Organization (A.2-A.3)

Detailed guidance on implementing Annex A controls for AI policies (A.2) and internal organization (A.3), including 6 controls with audit questions and implementation tips.

20 min read

Chapter Overview

Description

This chapter covers the first two control domains in Annex A: Policies for AI (A.2) and Internal Organization (A.3). These foundational controls establish governance structures and accountability for AI management.

Understanding Annex A

Annex A Structure

Annex A contains 39 controls across 9 domains:

• A.2 Policies for AI (2 controls)
• A.3 Internal Organization (4 controls)
• A.4 Resources for AI Systems (4 controls)
• A.5 Assessing Impacts (4 controls)
• A.6 AI System Life Cycle (12 controls)
• A.7 Data for AI Systems (5 controls)
• A.8 Information for Interested Parties (4 controls)
• A.9 Use of AI Systems (3 controls)
• A.10 Third-Party Relationships (3 controls)

A.2 Policies for AI

This domain establishes the policy framework for AI governance with 2 controls.

A.2.2 AI Policy

AttributeDetails
ControlPolicies for AI shall be defined, approved by management, published, communicated to relevant personnel and relevant interested parties, and acknowledged.
PurposeEstablish management direction and commitment for AI governance
Related Clause5.2 (AI Policy)

Implementation Guidance

  • Develop AI policy aligned with organizational strategy
  • Include responsible AI principles
  • Define scope and applicability
  • Obtain formal management approval
  • Publish on accessible platforms (intranet, website)
  • Communicate through multiple channels
  • Implement acknowledgment mechanism (training sign-off, digital acceptance)

Evidence Examples

  • Approved AI policy document with signatures
  • Publication records (intranet, website)
  • Communication records (emails, training)
  • Acknowledgment records (signed forms, system logs)
Audit Questions - A.2.2

• Show me your AI policy
• Who approved the policy and when?
• How is the policy communicated to personnel?
• How do staff acknowledge the policy?
• How is the policy made available to external interested parties?

A.2.3 Review of the Policies for AI

AttributeDetails
ControlPolicies for AI shall be reviewed at planned intervals or if significant changes occur to ensure their continuing suitability, adequacy, and effectiveness.
PurposeEnsure policies remain current and effective
Related Clause9.3 (Management Review)

Implementation Guidance

  • Define review frequency (typically annual)
  • Establish triggers for unscheduled reviews (regulatory changes, incidents, organizational changes)
  • Assign review responsibility
  • Document review process and outcomes
  • Update policies based on review findings
  • Re-communicate updated policies

Review Triggers

Trigger TypeExamples
PlannedAnnual review cycle
RegulatoryNew AI regulations (EU AI Act)
IncidentSignificant AI incidents
OrganizationalMergers, restructuring, strategy changes
TechnologyNew AI capabilities, significant system changes
AuditFindings from internal/external audits
Audit Questions - A.2.3

• When was the AI policy last reviewed?
• What is your planned review frequency?
• What triggers an unscheduled policy review?
• Show me evidence of the last review
• What changes were made as a result of the review?

A.3 Internal Organization

This domain establishes organizational structures and responsibilities for AI governance with 4 controls.

A.3.2 Roles and Responsibilities

AttributeDetails
ControlRoles and responsibilities relevant to the development, provision, or use of AI systems shall be defined and allocated according to organization needs.
PurposeEnsure clear accountability for AI activities
Related Clause5.3 (Roles, responsibilities and authorities)

Implementation Guidance

  • Identify all AI-related roles
  • Define responsibilities for each role
  • Document in job descriptions or responsibility matrix
  • Allocate roles to specific individuals
  • Communicate assignments
  • Review when organizational changes occur

Key AI Roles

RoleTypical Responsibilities
AIMS OwnerOverall AIMS accountability, reporting to management
AI System OwnerAccountability for specific AI system governance
AI Risk OwnerOwnership of AI-related risks
AI DeveloperDevelopment according to standards and controls
Data OwnerQuality and governance of AI training data
AI Ethics LeadResponsible AI principles and guidance
AI AuditorIndependent assessment of AI systems and AIMS
Audit Questions - A.3.2

• How are AI roles and responsibilities defined?
• Show me documentation of AI-related responsibilities
• Who is the owner of [specific AI system]?
• How do personnel know their AI responsibilities?
• How are responsibilities updated when changes occur?

A.3.3 Reporting

AttributeDetails
ControlPersonnel shall report observed or suspected AI-related incidents, vulnerabilities, or risks following defined procedures.
PurposeEnable timely identification and response to AI issues
Related Clause7.4 (Communication)

Implementation Guidance

  • Establish reporting procedures
  • Define what should be reported (incidents, near-misses, vulnerabilities, risks)
  • Provide multiple reporting channels (email, portal, hotline)
  • Enable anonymous reporting if appropriate
  • Train personnel on reporting procedures
  • Acknowledge and track reports
  • Protect reporters from retaliation

Reportable Events

CategoryExamples
IncidentsAI system failures, incorrect outputs, security breaches
Near-missesPotential failures caught before impact
VulnerabilitiesDiscovered weaknesses, potential attack vectors
RisksNewly identified risks, changing risk levels
ConcernsEthical concerns, bias observations, compliance issues
Audit Questions - A.3.3

• How do personnel report AI-related incidents?
• What reporting channels are available?
• Show me your incident reporting procedure
• How are reports tracked and responded to?
• Are personnel trained on what and how to report?

A.3.4 Authorities

AttributeDetails
ControlResponsibilities and authorities for handling AI-related events shall be defined.
PurposeEnable effective response to AI events
Related Clause5.3 (Roles, responsibilities and authorities)

Implementation Guidance

  • Define authority levels for AI decisions
  • Establish escalation paths
  • Define who can approve AI deployments
  • Define who can halt or modify AI systems
  • Document decision-making authority
  • Ensure authorities match responsibilities

Authority Examples

Decision/ActionAuthority Level
Approve new AI system deploymentAI Governance Committee / CTO
Emergency AI system shutdownAI System Owner / On-call Lead
Accept AI risk above thresholdExecutive Risk Committee
Approve AI policy changesTop Management / Board
Approve AI vendor selectionProcurement + AI Governance
Audit Questions - A.3.4

• Who has authority to approve AI deployments?
• Who can shut down an AI system in an emergency?
• How are authorities documented?
• What is the escalation path for AI events?
• Show me evidence of authority exercised for a recent event

A.3.5 Coordination

AttributeDetails
ControlPersonnel involved in AI systems within the organization shall coordinate their activities.
PurposeEnsure effective collaboration across AI activities
Related Clause7.4 (Communication)

Implementation Guidance

  • Establish coordination mechanisms (meetings, forums, committees)
  • Define interfaces between teams (development, operations, risk, compliance)
  • Create AI governance committee or working group
  • Implement collaboration tools and platforms
  • Share lessons learned across teams
  • Coordinate change management across dependent systems

Coordination Mechanisms

MechanismPurposeFrequency
AI Governance CommitteeStrategic oversight, policy decisionsMonthly/Quarterly
AI Working GroupOperational coordination, issue resolutionWeekly/Bi-weekly
Cross-functional ReviewsAI system reviews with multiple stakeholdersPer project/release
Incident Response TeamCoordinate response to AI incidentsAs needed
Community of PracticeShare knowledge, best practicesMonthly
Audit Questions - A.3.5

• How do AI teams coordinate their activities?
• What governance committees or forums exist?
• How do development and operations teams coordinate?
• How are cross-functional dependencies managed?
• Show me evidence of coordination activities

Control Implementation Summary

ControlKey EvidenceCommon Gaps
A.2.2 AI PolicyApproved policy, communication records, acknowledgmentsNo acknowledgment process
A.2.3 Policy ReviewReview records, change historyNo defined review schedule
A.3.2 RolesRole definitions, assignments, job descriptionsRoles not formally documented
A.3.3 ReportingReporting procedure, training records, incident logsNo reporting mechanism
A.3.4 AuthoritiesAuthority matrix, approval recordsAuthorities not documented
A.3.5 CoordinationMeeting records, committee terms of referenceNo formal coordination
Key Takeaways - A.2 & A.3

1. AI policy must be approved, published, communicated, AND acknowledged
2. Policies require planned reviews and trigger-based reviews
3. All AI-related roles must be defined and allocated
4. Reporting procedures enable personnel to flag AI issues
5. Authorities must be defined for AI decisions and events
6. Coordination ensures effective collaboration across teams

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