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ISO 42001 vs ISO 27001 — The Standards-Stack Comparison for AI and Information Security
ISO/IEC 27001:2022 and ISO/IEC 42001:2023 are two management system standards of ISO and IEC. ISO/IEC 27001 gives requirements for an information security management system (ISMS). Its risk assessment identifies risks to the confidentiality, integrity, and availability of information in the scope of the ISMS (6.1.2 c)).
ISO/IEC 42001 gives requirements and guidance for an AI management system. It is for each organization that supplies or uses products or services that use AI systems (Clause 1).
The two standards use the same structure for management system standards, and each standard keeps its own requirements. The Summary shows how an organization can use one management system for the two standards.
Where to start
ISO/IEC 27001 and ISO/IEC 42001 do not set a sequence. The points below are the advice of this page for an organization that plans to use one or the two standards:
- An organization can use each standard without the other. ISO/IEC 27001 names ISO/IEC 27000 as its normative reference, and ISO/IEC 42001 names ISO/IEC 22989 (Clause 2 of each). Annex D.2 of ISO/IEC 42001 is informative and sets no ISMS requirement.
- The organization has an ISMS. The organization can add ISO/IEC 42001 to the same management system (ISO/IEC 27001, 0.2). ISO/IEC 42001 then adds its requirements for AI, for example the AI policy and the AI system impact assessment. Conformity with ISO/IEC 27001 does not show conformity with ISO/IEC 42001, because each internal audit gives information on conformity with its own standard (9.2.1 a)). See Clauses 4 to 10 of the two standards.
- The organization has no management system. The organization can start with the standard that meets its needs. ISO/IEC 27001 gives requirements for information security management, and ISO/IEC 42001 gives requirements for AI management.
- The organization also manages privacy information. ISO/IEC 27701:2025 is a stand-alone management system standard for a privacy information management system (PIMS). It lets an organization align or integrate its PIMS with an ISMS of ISO/IEC 27001 (ISO/IEC 27701, 0.2). See Use with ISO/IEC 27001 and ISO/IEC 42001.
Summary
ISO/IEC 27001 and ISO/IEC 42001 are standards that an organization selects. The two standards are not law:
- ISO/IEC 27001:2022 is the third edition, of 2022-10. ISO published Amendment 1:2024, "Climate action changes", to this edition. The standard gives requirements for an ISMS. Its Annex A (normative) has information security controls in four themes. See The standard and its edition.
- ISO/IEC 42001:2023 is the first edition, of 2023-12. It gives requirements and guidance for an AI management system to all organizations that supply or use products or services that use AI systems (Clause 1).
- One management system: ISO/IEC 27001 applies the structure of Annex SL of the ISO/IEC Directives (0.2). ISO/IEC 42001 calls the same structure the harmonized structure (Introduction). An organization can operate one management system for the two standards, if the system conforms to the requirements of each standard (ISO/IEC 27001, 0.2). For conformity with ISO/IEC 27001, an organization cannot exclude a requirement in Clauses 4 to 10 (Clause 1). See ISO/IEC 27001 and ISO/IEC 42001.
The two standards side by side
| Item | ISO/IEC 27001:2022 | ISO/IEC 42001:2023 |
|---|---|---|
| Publisher | ISO and IEC (ISO/IEC JTC 1/SC 27) | ISO and IEC (ISO/IEC JTC 1/SC 42) |
| Edition | Third edition, 2022-10, with Amendment 1:2024 | First edition, 2023-12 |
| Type | Requirements for an ISMS | Requirements and guidance for an AI management system |
| What the standard is for | Information in the scope of the ISMS (6.1.2 c)). Annex A controls also apply to other assets related to information (for example 5.9). | AI systems that the organization develops, supplies, or uses, in the scope that it sets for its AI management system (Clause 1, 4.3) |
| Legal status | Not law. The organization selects the standard. | Not law. The organization selects the standard. |
| Structure | Clauses 4 to 10 in the structure of Annex SL (0.2). Annex A (normative), "Information security controls reference". | Clauses 4 to 10 in the harmonized structure (Introduction). Annex A (normative), Annex B (normative) with implementation guidance, and Annexes C and D (informative). |
| Annex A | Four themes: "Organizational controls" (5), "People controls" (6), "Physical controls" (7), and "Technological controls" (8) | Nine areas. A.2 to A.6: Policies related to AI, Internal organization, Resources for AI systems, Assessing impacts of AI systems, and AI system life cycle. A.7 to A.10: Data for AI systems, Information for interested parties of AI systems, Use of AI systems, and Third-party and customer relationships. |
| Risks and impacts | Information security risk assessment (6.1.2, 8.2) and risk treatment with a Statement of Applicability (6.1.3, 8.3) | AI risk assessment (6.1.2, 8.2), AI risk treatment with a statement of applicability (6.1.3, 8.3), and AI system impact assessment (6.1.4, 8.4) |
| Certification | The standard sets no certification procedure. Certification by a certification body is optional (Certification). | The standard sets no certification procedure. Certification by a certification body is optional (Certification). |
| Other standards | Compatible with other management system standards that use Annex SL (0.2). ISO/IEC 27701:2025 lets an organization align or integrate its PIMS with an ISMS (ISO/IEC 27701, 0.2). | Compatible with other management system standards through the harmonized structure (Introduction). Annex D.2 names ISO 9001, ISO/IEC 27001, and ISO/IEC 27701. The notes to 6.1.1 refer to ISO/IEC 23894 for guidance on AI risk management. |
Clauses 4 to 10 of the two standards
ISO/IEC 27001 and ISO/IEC 42001 put Clauses 4 to 10 in the same sequence. In each clause, the requirements of each standard apply to its own management system. The table shows the primary differences:
| Clause | ISO/IEC 27001:2022 | ISO/IEC 42001:2023 |
|---|---|---|
| 4 "Context of the organization" | Issues, interested parties, and scope of the ISMS. For the scope, the organization also considers interfaces and dependencies with activities of other organizations (4.3 c)). | Issues, interested parties, and scope of this management system. The organization also considers the intended purpose of its AI systems and determines its roles for them (4.1). |
| 5 "Leadership" | Information security policy (5.2) | AI policy (5.2) |
| 6 "Planning" | Information security risk assessment (6.1.2), risk treatment (6.1.3), information security objectives (6.2), and planning of changes (6.3). Clause 6.1.3 d) gives the content of the Statement of Applicability. | AI risk assessment (6.1.2), AI risk treatment (6.1.3), and AI system impact assessment (6.1.4). Clause 6.1.3 f) gives the content of the statement of applicability. AI objectives (6.2) and planning of changes (6.3). |
| 7 "Support" | Resources, competence, awareness, communication, and documented information (7.1 to 7.5) | The same subjects (7.1 to 7.5), for the AI management system |
| 8 "Operation" | "Operational planning and control" (8.1). The organization does information security risk assessments (8.2) and the work in its risk treatment plan (8.3). | "Operational planning and control" (8.1). The organization does AI risk assessments (8.2) and AI system impact assessments (8.4). It does the work in its AI risk treatment plan and verifies its effectiveness (8.3). |
| 9 "Performance evaluation" | "Monitoring, measurement, analysis and evaluation" (9.1), internal audit (9.2), and management review (9.3) | The same subclauses (9.1 to 9.3), with the differences that follow the table |
| 10 "Improvement" | Continual improvement (10.1), and nonconformity and corrective action (10.2) | The same subclauses (10.1, 10.2) |
ISO/IEC 42001 adds the AI system impact assessment (6.1.4). The organization documents the result of each AI system impact assessment, and it considers the result in its AI risk assessment (6.1.4).
Clause 9 is not the same in the two standards:
- Monitoring and measurement: ISO/IEC 27001 9.1 adds items that ISO/IEC 42001 9.1 does not have. What the organization monitors and measures includes information security processes and controls (a)). ISO/IEC 27001 recommends methods that give results that the organization can compare and reproduce (b)). The organization determines who monitors and measures (d)), and who analyzes and evaluates the results (f)).
- Internal audit: ISO/IEC 42001 9.2.2 a) adds audit objectives to the audit criteria and scope of each audit.
- Management review: ISO/IEC 27001 9.3.2 has three types of inputs that ISO/IEC 42001 9.3.2 does not have:
- the fulfillment of information security objectives (d) 4))
- feedback from interested parties (e))
- the results of risk assessment and the status of the risk treatment plan (f))
Where the two standards agree and where they are different
ISO/IEC 27001 and ISO/IEC 42001 each have a normative Annex A. In each standard, the organization uses Annex A to check the controls of its risk treatment:
- ISO/IEC 42001: not all Annex A controls are mandatory, and the organization can make its own controls (A.1). The organization determines the necessary controls in its AI risk treatment, and it compares them with Annex A (6.1.3 b)).
- ISO/IEC 27001: the organization determines the necessary controls and compares them with Annex A (6.1.3 b) and c)). Its Statement of Applicability gives a justification for each Annex A control that it excludes (6.1.3 d)).
Annex A of ISO/IEC 27001 and Annex A of ISO/IEC 42001 have only a small number of subjects that are the same:
- Suppliers: ISO/IEC 27001 5.19 to 5.23, and ISO/IEC 42001 A.10.3.
- Monitoring: ISO/IEC 27001 8.16, and ISO/IEC 42001 A.6.2.6 (operation and monitoring of the AI system).
- Incidents: ISO/IEC 27001 has five controls for information security incidents (5.24 to 5.28). ISO/IEC 42001 has one control, a plan to tell users of the AI system about incidents (A.8.4).
- Access control and change management: ISO/IEC 27001 has controls for them (5.15, 8.32). ISO/IEC 42001 Annex A has no control for them.
In Modulos, the ISO 27001 Framework with the Annex A Requirements (MFF-9) shares no Control with the two ISO 42001 Frameworks. See ISO/IEC 42001 and ISO/IEC 27001 in Modulos.
ISO/IEC 27001 has no AI-specific requirements. Its information security requirements apply to information in the ISMS scope, also when AI systems process that information (Clause 1, 6.1.2 c)). ISO/IEC 42001 adds AI risk assessment (6.1.2), AI system impact assessment (6.1.4), and controls for the life cycle of AI systems (A.6).
ISO/IEC 42001 sets no ISMS requirement (Annex D.2) and recommends that organizations identify AI-specific information security threats (B.6.2.6). See Annexes B and D.
ISO/IEC 42001 and ISO/IEC 27001 in Modulos
Modulos has different Frameworks for ISO/IEC 27001 and ISO/IEC 42001, at two levels:
| Framework in Modulos | Organization level | AI System level |
|---|---|---|
| ISO 27001 | OFF-9: Clauses 4.1 to 10.2 without 8.2 and 8.3, and no Annex A controls | MFF-9: Clauses 8.2 and 8.3, and the four Annex A themes |
| ISO 42001 | OFF-10 (Requirement table) | MFF-10 (Requirement table) |
To set up the two standards, do these steps:
- Add
OFF-9andOFF-10to the organization AI System. - If the organization AI System is not available in your account, contact Modulos.
- For each AI system in scope, add
MFF-9andMFF-10to its AI System in Modulos. - Follow the Requirement procedure for each Framework.
The Requirements of each Framework are on Operationalizing ISO/IEC 27001 in Modulos and Operationalizing ISO/IEC 42001 in Modulos.
The ISO 27001 and ISO 42001 Frameworks share Controls only at the Organization level:
- Organization level:
OFF-9andOFF-10share 60 Controls. These are 87% of the Controls ofOFF-9and 80% of the Controls ofOFF-10. - AI System level:
MFF-9andMFF-10share no Control.
Your team does the work of a shared Control one time, and its Evidence serves each Framework with a Requirement that maps the Control. The Requirement of the other Framework does not become Fulfilled because of a shared Control. The Requirement Owner of each Framework does a Review of its own Requirement. Control overlap gives the shared Controls of each pair of Frameworks.
Where to go next
ISO/IEC 27001 guide
Information security management system, Clauses 4 to 10, Annex A, certification
ISO/IEC 42001 guide
AI management system, Clauses 4 to 10, Annexes A to D, certification
ISO/IEC 27701 guide
Privacy information management system and its use with ISO/IEC 27001 and ISO/IEC 42001
ISO 42001 vs NIST AI RMF
The ISO/IEC 42001 clauses next to the four functions of NIST AI RMF
Control overlap
How many Controls two Modulos Frameworks share at each level
Frameworks compared
Status and scope of each framework that Modulos documents
Sources of this page
- ISO/IEC 27001:2022, Information security, cybersecurity and privacy protection — Information security management systems — Requirements, third edition, 2022-10 (ISO catalog page). Used: the Foreword, and the Introduction (0.1 and 0.2). Clauses: 1, 2, 4.3, 5.2, 6.1.2, 6.1.3, 6.2, 6.3, 7.1 to 7.5, 8.1 to 8.3, 9.1 to 9.3, 10.1, and 10.2. Annex A: 5.9, 5.15, 5.19 to 5.28, 8.16, and 8.32.
- ISO/IEC 27001:2022/Amd 1:2024, "Climate action changes" (ISO catalog page). Used: the title and the publication date.
- ISO/IEC 42001:2023 (first edition, 2023-12), Information technology — Artificial intelligence — Management system (ISO catalog page). Used: the Foreword and the Introduction. Clauses: 1, 2, 4.1, 4.3, 5.2, 6.1.1 to 6.1.4, 6.2, 6.3, 7.1 to 7.5, 8.1 to 8.4, 9.1 to 9.3, 10.1, and 10.2. Annexes: A.1, the areas A.2 to A.10, A.6.2.6, A.8.4, A.10.3, B.6.2.6, and D.2.
- ISO/IEC 27701:2025, Information security, cybersecurity and privacy protection — Privacy information management systems — Requirements and guidance, second edition, 2025-10 (ISO catalog page). Used: the Foreword and the Introduction (0.2).
Disclaimer
This page gives general information. It is not legal advice.