ISO/IEC 27001 — integration with AI governance

ISO/IEC 27001:2022 gives requirements for an information security management system (ISMS). The ISMS keeps the confidentiality, integrity, and availability of information through a risk management process (Introduction 0.1). This page shows how an ISMS applies to AI systems. It also shows how ISO/IEC 27001 is different from ISO/IEC 42001:2023, the standard for an AI management system. It gives examples of Annex A controls in areas that are also areas of AI governance, and compares the standard with some EU obligations.

Information security of AI systems in an ISMS

ISO/IEC 27001:2022 has no requirement that is special to AI systems. The requirements of Clauses 4 to 10 are for use by all organizations, large or small and of all types (Clause 1). These two requirements show which information is in the ISMS:

• The organization determines the boundaries and applicability of its ISMS to set the scope of the ISMS (Clause 4.3).
• The information security risk assessment identifies the risks to the confidentiality, integrity, and availability of the information in that scope. It also identifies the risk owners (Clause 6.1.2 c)).

Thus the information of an AI system is in the ISMS only if it is in the scope that the organization determines. The standard has one ISMS for the organization, not one ISMS for each AI system. For the scope, see The scope of the ISMS (Clause 4.3).

ISO/IEC 42001:2023 Annex D.1 (informative) tells the organization that information security applies to AI in general, because AI processes information.

ISO/IEC 27001 and ISO/IEC 42001

ISO/IEC 27001:2022 and ISO/IEC 42001:2023 are two different standards. ISO/IEC 27001 gives requirements for an ISMS. ISO/IEC 42001 gives requirements for an AI management system. One standard does not require the other standard:

• The only normative reference of ISO/IEC 27001 is ISO/IEC 27000 (ISO/IEC 27001 Clause 2).
• The only normative reference of ISO/IEC 42001 is ISO/IEC 22989 (ISO/IEC 42001 Clause 2).
• ISO/IEC 42001 Annex D.2 (informative) tells the organization that it can implement an ISMS in conformity with ISO/IEC 27001. This applies if the organization finds it necessary to apply the same full method to its information security objectives as to its AI management system. Annex D.2 also tells the organization that the same harmonized structure helps it to use the two standards together.

Thus the integration of the two management systems is a decision of the organization. The two standards use the harmonized structure for Clauses 4 to 10, and an organization can operate one management system for the two standards (ISO/IEC 27001 Introduction 0.2). But each standard keeps its requirements. The internal audit of each standard must give information on conformity with the requirements of that standard (Clause 9.2.1 of each standard). Top management must review each management system (Clause 9.3.1 of each standard). For one management system for more than one standard, see Use with ISO/IEC 42001 and ISO/IEC 27701.

NOTE 2 to ISO/IEC 42001 Clause 6.1.3 tells the organization that it can put its AI risk management into other management systems, if applicable.

The two standards each have a normative Annex A, and each requires a statement of applicability:

Standard	Annex A	Statement of applicability
ISO/IEC 27001:2022	Normative	Clause 6.1.3 d): the necessary controls, the justification for their inclusion, if the organization implements each necessary control, and a justification for each Annex A control that the organization excludes
ISO/IEC 42001:2023	Normative	Clause 6.1.3 f): the necessary controls, and a justification for each control that the organization includes or excludes

The Annex A controls of ISO/IEC 27001 are not the controls of ISO/IEC 42001 Annex A. To compare the two standards clause by clause, see ISO/IEC 42001 and ISO/IEC 27001 compared.

Annex A controls and AI governance

ISO/IEC 27001:2022 Annex A has controls for areas that are also areas of AI governance. This table gives examples:

Area	Annex A controls
Threat intelligence	A.5.7
Classification of information	A.5.12
Suppliers, the ICT supply chain, and cloud services	A.5.19 to A.5.23
Information security incidents	A.5.24 to A.5.28
Privacy and protection of PII	A.5.34
Awareness and training	A.6.3
Configuration management	A.8.9
Deletion, masking, and data leakage	A.8.10 to A.8.12
Logging and monitoring	A.8.15 and A.8.16
Cryptography	A.8.24
Development of software and systems	A.8.25 to A.8.28

These controls apply through the information security risk treatment of Clause 6.1.3, as all Annex A controls do. A control in this table applies only if the risk treatment of the organization makes it necessary. For the procedure, see How Annex A applies through risk treatment (Clause 6.1.3).

ISO/IEC 27001 and the EU AI Act

Regulation (EU) 2024/1689 (the EU AI Act) does not name ISO/IEC 27001 or ISO/IEC 42001. The Act gives its obligations to the persons that it names, for example providers and deployers, with time limits for some obligations. Two examples are the cybersecurity of high-risk AI systems (Article 15(5)) and the report of a serious incident (Article 73). The use of an Annex A control is not the same as compliance with an obligation of the Act. For these obligations and the dates from which they apply, see High-risk AI systems and Post-market monitoring and serious incidents.

Other EU laws also have obligations for information security and for reports: Directive (EU) 2022/2555 (NIS2), Articles 21 and 23, and Regulation (EU) 2016/679 (GDPR), Articles 32 and 33. The incident management controls of Annex A (A.5.24 to A.5.28) are for the incident management of the organization. The obligations to report in NIS2 Article 23, GDPR Article 33, and EU AI Act Article 73 apply to the persons that each law names, and each law sets time limits for its reports. For these laws, see NIS2 cybersecurity measures, NIS2 incident reports, and GDPR Articles 32 and 33. None of these laws makes ISO/IEC 27001 or its certification necessary (ISO/IEC 27001 and EU law).

AI governance in Modulos

Modulos has two Frameworks for ISO/IEC 27001, each with the name ISO 27001: OFF-9 at the Organization level and MFF-9 at the AI System level (ISO/IEC 27001 in Modulos). ISO/IEC 42001 and the EU AI Act have different Frameworks. See Other management system standards in Modulos, ISO/IEC 42001 in Modulos, and EU AI Act in Modulos.

Each Framework contains the Requirements of one instrument. Add the Frameworks of each instrument that applies to your organization. For the Controls that are in two or more Frameworks, see Control overlap.

Where to go next

ISO 27001 overview

The standard, its structure, its use with ISO/IEC 42001 and ISO/IEC 27701, and EU law

Annex A (controls reference)

93 controls in four themes, and how they apply through risk treatment

ISO 42001 overview

The standard for an AI management system, with its normative Annex A

EU AI Act overview

The scope of the Act, high-risk AI systems, and the obligations of the Act

ISO 42001 vs ISO 27001 comparison

The two standards, side by side

ISO 27001 in Modulos

The Frameworks, the steps to set them up, and the Requirement table

Sources of this page

• ISO/IEC 27001:2022, edition 3, 2022-10 (ISO catalog page). The Introduction (0.1 and 0.2). Clauses 1, 2, 4.3, 6.1.2 c), 6.1.3, 9.2.1, and 9.3.1. Annex A: A.5.7, A.5.12, A.5.19 to A.5.28, A.5.34, A.6.3, A.8.9 to A.8.12, A.8.15, A.8.16, and A.8.24 to A.8.28.
• ISO/IEC 42001:2023, edition 1, 2023-12 (ISO Online Browsing Platform). Clause 2, Clause 6.1.3 (NOTE 2 and item f)), Clauses 9.2.1 and 9.3.1, Annex A, and Annex D.1 and D.2.
• Regulation (EU) 2024/1689 (EU AI Act), consolidated text of 27 July 2026. Article 15(5), Article 16(a), and Article 73 (EUR-Lex).
• Directive (EU) 2022/2555 (NIS2). Articles 21 and 23 (EUR-Lex).
• Regulation (EU) 2016/679 (GDPR). Articles 32 and 33 (EUR-Lex).

Disclaimer

This page gives general information only. It is not legal advice, and it does not replace the audit of a certification body.