Chapter 25

Internal Audit Guide

Complete guide to planning and conducting internal audits of the AI Management System including audit program, checklists, and reporting.

20 min read

Chapter Overview

This chapter provides a comprehensive guide to planning and conducting internal audits of your AIMS as required by Clause 9.2. Effective internal audits are essential for verifying conformance and driving improvement.

Clause 9.2 Requirements

The organization shall conduct internal audits at planned intervals to provide information on whether the AIMS:
• Conforms to the organization's own requirements
• Conforms to the requirements of ISO 42001
• Is effectively implemented and maintained

Audit Program

Audit Program Elements

ElementDescription
ObjectivesWhat the audit program aims to achieve
ScopeWhat will be audited over the program period
ScheduleWhen audits will be conducted
ResourcesAuditors, time, budget
MethodologyHow audits will be conducted
ReportingHow results will be reported

Audit Frequency Factors

FactorHigher Frequency Needed
Risk LevelHigh-risk AI systems
Previous ResultsAreas with past nonconformities
ChangesRecently changed processes or systems
MaturityNew or immature processes
RegulatoryHeavily regulated areas
ImportanceCritical processes

Annual Audit Schedule Template

Sample Annual Audit Plan

Q1: Clauses 4-5 (Context, Leadership), A.2-A.3 (Policy, Organization)
Q2: Clause 6 (Planning), A.5-A.6 (Impacts, Lifecycle)
Q3: Clauses 7-8 (Support, Operation), A.7-A.8 (Data, Transparency)
Q4: Clauses 9-10 (Performance, Improvement), A.9-A.10 (Use, Third-party)

Ensure all clauses and applicable Annex A controls are covered at least annually.

Audit Process

Audit Phases

PhaseActivitiesOutput
1. PlanningDefine scope, criteria, schedule, teamAudit plan
2. PreparationReview documentation, prepare checklistsAudit checklist
3. Opening MeetingConfirm scope, explain processMeeting record
4. Evidence GatheringInterviews, document review, observationAudit notes
5. AnalysisEvaluate evidence against criteriaFindings
6. Closing MeetingPresent findings, agree actionsMeeting record
7. ReportingDocument audit resultsAudit report
8. Follow-upVerify corrective actionsClosure records

Audit Planning

Audit Plan Content

Audit Plan Template

Audit Reference: [Unique ID]
Audit Date(s): [Dates]
Audit Type: [Internal/Surveillance/Certification]

Scope:
• Clauses to be audited
• Annex A controls to be audited
• AI systems in scope
• Locations/departments

Criteria:
• ISO 42001:2023
• Organization's AIMS documentation
• Applicable regulations

Audit Team:
• Lead Auditor: [Name]
• Auditor(s): [Names]

Schedule:
• [Time] - Opening meeting
• [Time] - [Area/Process]
• [Time] - [Area/Process]
• [Time] - Closing meeting

Auditees: [Names and roles]

Evidence Gathering

Evidence Types

TypeExamples
DocumentationPolicies, procedures, records, reports
InterviewsDiscussions with personnel at all levels
ObservationWatching processes being performed
System ReviewExamining AI systems, tools, dashboards
SamplingSelecting samples of records or outputs

Interview Techniques

  • Use open-ended questions (what, how, why, show me)
  • Ask for evidence to support statements
  • Follow audit trails
  • Verify understanding by summarizing
  • Remain objective and non-judgmental
  • Take clear notes

Audit Checklist - ISO 42001

Clause 4: Context

Clause 4 Audit Questions

☐ Are external and internal issues identified? (4.1)
☐ Are interested parties and their requirements identified? (4.2)
☐ Is the AIMS scope documented and available? (4.3)
☐ Is the AIMS established and maintained? (4.4)
☐ Are process interactions defined? (4.4)

Clause 5: Leadership

Clause 5 Audit Questions

☐ Is there evidence of top management commitment? (5.1)
☐ Is the AI policy documented and approved? (5.2)
☐ Is the policy communicated and available? (5.2)
☐ Are roles and responsibilities assigned and communicated? (5.3)
☐ Is someone responsible for AIMS conformance and reporting? (5.3)

Clause 6: Planning

Clause 6 Audit Questions

☐ Is there a documented risk assessment process? (6.1.2)
☐ Are risk criteria established? (6.1.2)
☐ Do assessments cover the AI lifecycle? (6.1.2)
☐ Is there a documented risk treatment process? (6.1.3)
☐ Is there a Statement of Applicability? (6.1.3)
☐ Does the SoA justify exclusions? (6.1.3)
☐ Is there an approved risk treatment plan? (6.1.3)
☐ Are AI objectives established and measurable? (6.2)

Clause 7-10 Summary

Clauses 7-10 Key Questions

Clause 7 (Support):
☐ Are adequate resources provided?
☐ Is competence determined and evidenced?
☐ Is awareness training provided?
☐ Are communications planned?
☐ Is documented information controlled?

Clause 8 (Operation):
☐ Are operational controls implemented?
☐ Are risk assessments conducted as planned?
☐ Are risk treatments implemented?
☐ Are impact assessments conducted?

Clause 9 (Performance):
☐ Is performance monitored and measured?
☐ Is there an internal audit program?
☐ Are management reviews conducted?

Clause 10 (Improvement):
☐ Are nonconformities addressed?
☐ Are corrective actions effective?
☐ Is continual improvement demonstrated?

Audit Findings

Finding Classifications

ClassificationDefinitionResponse Required
Major NonconformityAbsence or total breakdown of requirement; systemic failureImmediate corrective action required
Minor NonconformitySingle lapse or partial non-fulfilmentCorrective action required
ObservationArea for improvement; not a nonconformityConsider for improvement
Positive FindingGood practice observedShare and maintain

Writing Findings

Good Finding Format

Requirement: [Specific clause or control requirement]
Evidence: [Objective evidence observed]
Finding: [Clear statement of conformity or nonconformity]

Example:
Requirement: Clause 6.1.3 requires a Statement of Applicability with justification for exclusions.
Evidence: The SoA dated 2024-01-15 excludes control A.7.5 (Data Preparation) with no justification provided.
Finding: Minor nonconformity - SoA does not include justification for excluded control.

Audit Report

Report Content

Audit Report Template

1. AUDIT DETAILS
• Audit reference and date
• Audit scope and criteria
• Audit team
• Auditees

2. EXECUTIVE SUMMARY
• Overall assessment
• Number of findings by type
• Key observations

3. AUDIT FINDINGS
For each finding:
• Finding reference
• Classification (Major/Minor/Observation)
• Requirement
• Evidence
• Finding statement

4. POSITIVE OBSERVATIONS
• Good practices noted

5. CONCLUSION
• Audit objectives achieved?
• AIMS conformance assessment
• Recommendations

6. DISTRIBUTION
• Recipients of report

7. SIGN-OFF
• Lead Auditor signature and date

Auditor Competence

Required Competencies

AreaCompetence Needed
Audit SkillsISO 19011 audit principles and techniques
ISO 42001Understanding of all requirements
AI KnowledgeBasic understanding of AI systems and risks
OrganizationKnowledge of organization context
CommunicationInterview and reporting skills

Independence Requirements

  • Auditors must not audit their own work
  • Independence from area being audited
  • No conflicts of interest
  • Objective and impartial
Key Takeaways - Internal Audit

1. Audit program must cover all clauses and applicable controls
2. Audits verify conformance AND effectiveness
3. Auditors must be competent and independent
4. Findings must be evidence-based
5. Follow up on corrective actions
6. Internal audit is preparation for certification

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