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AI Policy Template (ISO/IEC 42001 AIMS, EU AI Act)

Top-level AIMS policy: clause 5.2 commitments, principles, objectives, roles, prohibited uses (AI Act Art. 5), assessments, suppliers, AI literacy

ISO & KonformitätVollständigISO/IEC 42001:2023 clauses 5.2, 5.3, 6.2, Annex A.2; Regulation (EU) 2024/1689 as amended by 2026/1744, Article 5iso42001policy

Anleitung: Use it to write the governing AI policy that top management signs for an AI management system. Fill scope, AI roles and the prohibited uses list first, and link staff tool rules to the AI acceptable use policy instead of repeating them. The main pitfall is a values list with no testable commitment or owner.

Vorschau

AI Policy: [Organisation name]

Top-level AI policy for an AI management system (AIMS), structured on clause 5.2 of ISO/IEC 42001:2023 and Annex A control objective A.2, with roles under clause 5.3 and a framework for AI objectives under clause 6.2. It states the organisation's commitments for developing, providing and using AI systems, the responsible AI principles, the prohibited and restricted uses (aligned with Article 5 of the EU AI Act, Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744), and the duties for risk and impact assessment, data, third parties, transparency, incidents and AI literacy. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice.

Document control

FieldValue
Document ID[POL-AIMS-001]
Version[1.0]
Status[Draft / In review / Approved / Superseded]
Owner[@ai-governance-lead]
Approvers / reviewers[@ceo], [@ai-governance-board], [@legal], [@ciso], [@dpo]
Last updatedYYYY-MM-DD
Classification[Public / Internal]
Effective dateYYYY-MM-DD
Next scheduled reviewYYYY-MM-DD
Organisation's AI roles[Provider / Deployer / Importer / Distributor / AI customer / AI producer]
AIMS scope statement[SCOPE-AIMS-001]

Approvals

RoleNameDecisionDate
Chief executive (top management)[@name][Approve / Reject]YYYY-MM-DD
AI governance board chair[@name][Recommend for approval]YYYY-MM-DD
Legal counsel[@name][Reviewed]YYYY-MM-DD

Revision history

VersionDateAuthorChange summary
0.1YYYY-MM-DD[@name]First draft
1.0YYYY-MM-DD[@name]Example: Approved by the CEO
1.1YYYY-MM-DD[@name]Example: Section 8.2 updated for prohibitions added by Regulation (EU) 2026/1744

Contents

1. Purpose

This policy sets the direction and commitments of [Organisation name] for the responsible development, provision and use of artificial intelligence. It establishes the AI management system, gives the framework within which AI objectives are set, and assigns accountability so that AI systems create value for [customers, citizens, patients or other beneficiaries] while risks to people, the organisation and society are identified and kept within accepted limits.

Example: As a provider of customer service software, we use AI to resolve customer requests faster. This policy makes sure that every AI feature we build or buy is safe, lawful, transparent to the people who use it, and supervised by accountable staff.

2. Scope

This policy applies to:

  • all AI systems that [Organisation name] designs, develops, trains, fine-tunes, provides, deploys, operates, buys or integrates, including AI features embedded in third-party software and general-purpose AI models used through an API;
  • all employees, contractors, temporary staff and partners who work with those systems on the organisation's behalf;
  • all locations and business units listed in [SCOPE-AIMS-001].
AI roleApplies to us?Examples in our organisation
Developer or provider of AI systems[Yes / No]Example: Support assistant sold to customers
Deployer or user of AI systems[Yes / No]Example: Fraud scoring tool used by the finance team
Integrator of third-party models[Yes / No]Example: Foundation model accessed by API in two products
Staff use of AI toolsYesGoverned by the AI acceptable use policy [POL-AI-USE-001]

Personal use of AI tools for work tasks is covered by the AI acceptable use policy, which implements section 8 of this policy for individual staff. Where the two conflict, this policy prevails.

3. Policy statement

Top management of [Organisation name] commits to:

  1. Develop, provide and use AI systems only for purposes that are lawful, documented and aligned with our values and this policy.
  2. Meet the legal, regulatory and contractual requirements that apply to our AI systems, including the EU AI Act where it applies to us, data protection law and sector rules.
  3. Identify, assess and treat AI risks and impacts before deployment and throughout the life of each system, and accept residual risk only at the authority level set in the risk methodology.
  4. Keep meaningful human oversight proportionate to the risk of each system.
  5. Be transparent with the people who use or are affected by our AI systems about the role AI plays and its limits.
  6. Provide the resources, competence and AI literacy measures needed to run the AIMS.
  7. Set, monitor and review AI objectives within the framework in section 6.
  8. Continually improve the suitability, adequacy and effectiveness of the AIMS.

Signed: [@ceo], [Chief executive officer], YYYY-MM-DD

4. How this policy meets clause 5.2

RefExpectation (paraphrase)Where met
5.2 aPolicy suits the organisation's purposeSections 1 and 2
5.2 bPolicy gives a framework for setting AI objectivesSection 6
5.2 cPolicy commits to meeting applicable requirementsSection 3 item 2; section 18
5.2 dPolicy commits to continual improvement of the AIMSSection 3 item 8; section 19
5.2 (documented information)Policy is available as documented informationDocument control; controlled document register
5.2 (other policies)Policy refers to related organisational policies where relevantSection 20
5.2 (communication)Policy is communicated within the organisationSection 16
5.2 (interested parties)Policy is available to interested parties as appropriateExample: Summary published on the trust centre page
A.2.2AI policy documentedThis document
A.2.3Other policies aligned with AI objectivesSection 20 alignment table
A.2.4AI policy reviewed at intervals and on changeSection 19

5. Responsible AI principles

IDPrincipleCommitmentPrimary controls
PR-01AccountabilityEvery AI system has a named business owner and technical owner recorded in the AI system inventoryA.3.2, A.4.2
PR-02Fairness and non-discriminationSystems that affect people are tested for performance differences across relevant groups before release and at least [annually]A.5.4, A.6.2.4, A.7.4
PR-03Transparency and explainabilityPeople are told when they interact with an AI system or receive AI-generated content, and can get an explanation proportionate to the decisionA.8.2, A.8.5
PR-04Safety and reliabilitySystems meet defined acceptance criteria before deployment and are monitored in operationA.6.2.4, A.6.2.6
PR-05SecurityAI-specific threats such as prompt injection, data poisoning and model theft are part of threat modelling and testingA.6.2.4, additional security controls
PR-06PrivacyPersonal data in training, prompts and outputs is processed lawfully, minimised and protectedA.7.2, A.7.6
PR-07Human oversightThe level of human control is set per system according to risk and documentedA.9.2, A.9.4
PR-08Data quality and provenanceData used for AI has documented origin, rights and quality criteriaA.7.3, A.7.4, A.7.5
PR-09Environmental responsibilityCompute and energy use are considered when choosing models and infrastructureA.4.5, A.5.5
PR-10ContestabilityPeople affected by AI-supported decisions can raise a concern or challenge the outcomeA.3.3, A.8.3

6. AI objectives framework

AI objectives are set at least [annually] by the AI governance board, proposed by owners of AI systems and functions, and approved by top management. Each objective must:

  • derive from at least one principle in section 5 or a requirement in the legal register;
  • have a measure, a target, an owner, the resources needed, a due date and the method for evaluating results;
  • be reviewed at each management review and updated when context changes.
Objective IDObjectivePrincipleMeasureTargetOwnerDueEvaluation
OBJ-AI-001 (Example)Complete an impact assessment for every AI system that affects external individualsPR-02, PR-10Share of in-scope systems with an approved assessment100%[@ai-governance-lead]YYYY-MM-DDQuarterly inventory check
OBJ-AI-002 (Example)Reduce unsupported claims in support assistant answersPR-04Groundedness failure rate on the evaluation setBelow [x]%[@head-of-ml]YYYY-MM-DDRelease evaluation report
OBJ-AI-003 (Example)Deliver role-based AI literacy measures to all staff who operate AI systemsPR-01, PR-07Share of in-scope staff with completed module[95]%[@hr-lead]YYYY-MM-DDLearning system report
OBJ-AI-004 (Example)Assess all AI suppliers before contract signaturePR-01, PR-05Share of new AI contracts with a completed vendor questionnaire100%[@procurement-lead]YYYY-MM-DDProcurement audit

7. Roles and responsibilities

RoleResponsibilities
Top managementApproves this policy, sets direction, provides resources, accepts residual risk above [level], chairs or attends management review
AI governance boardRecommends policy and objectives, approves high-risk use cases, reviews incidents and audit results, decides exceptions
AIMS managerRuns the AIMS, maintains the Statement of Applicability, reports performance to top management
AI system business ownerAccountable for the purpose, benefits and risks of a system; signs off impact assessments
AI system technical ownerResponsible for design, testing, deployment, monitoring and documentation of a system
Data ownerApproves data use for AI, rights and quality criteria
Legal and complianceMaintains the AI legal register; advises on AI Act roles, contracts and transparency
Data protection officerAdvises on personal data processing and DPIAs
Security leadOwns AI threat modelling, security testing and incident response for AI
ProcurementRuns third-party AI assessment and contract clauses
All staffFollow this policy and the AI acceptable use policy; report concerns and incidents
ActivityTop mgmtBoardAIMS mgrBusiness ownerTechnical ownerLegal
Approve AI policyARCIIC
Approve high-risk use caseIACRCC
Impact assessmentICCARC
Statement of ApplicabilityICA/RCCC
Incident notification to authoritiesIACCRR

8. Acceptable, restricted and prohibited uses

8.1 Acceptable uses

AI may be developed or used for a documented business purpose after the use case is registered through the AI use case intake process and the required reviews in section 9 are complete. Example: drafting customer replies for agent review, summarising internal documents, detecting anomalies in invoices, code assistance under the acceptable use policy.

8.2 Prohibited uses

[Organisation name] does not develop, provide, buy or use AI systems for any of the following practices. The list follows Article 5 of the AI Act, which has applied since 2 February 2025, and is extended by internal rules where marked.

IDProhibited practice (paraphrase)Source
PRH-01Subliminal, purposefully manipulative or deceptive techniques that materially distort a person's behaviour and cause or are likely to cause significant harmAI Act Art. 5(1)(a)
PRH-02Exploiting vulnerabilities linked to age, disability or a specific social or economic situation to materially distort behaviour with significant harmAI Act Art. 5(1)(b)
PRH-03Social scoring that leads to detrimental or unfavourable treatment in unrelated contexts or that is unjustified or disproportionateAI Act Art. 5(1)(c)
PRH-04Assessing or predicting the risk that a person will commit a crime based solely on profiling or personality traitsAI Act Art. 5(1)(d)
PRH-05Creating or expanding facial recognition databases through untargeted scraping of facial images from the internet or CCTVAI Act Art. 5(1)(e)
PRH-06Inferring emotions of people in the workplace or in education, except for medical or safety reasonsAI Act Art. 5(1)(f)
PRH-07Biometric categorisation to deduce race, political opinions, trade union membership, religious or philosophical beliefs, sex life or sexual orientationAI Act Art. 5(1)(g)
PRH-08Real-time remote biometric identification in publicly accessible spaces for law enforcement, outside the narrow exceptions in the ActAI Act Art. 5(1)(h)
PRH-09Generating or manipulating realistic intimate or sexually explicit images, video or audio of an identifiable person without consent, or child sexual abuse materialAdded by Regulation (EU) 2026/1744, applicable from 2 December 2026; check the consolidated text
PRH-10 (Example internal rule)Fully automated decisions to dismiss or discipline staffInternal rule
PRH-11 (Example internal rule)Entering secret or restricted data into AI tools not on the approved tools registerInternal rule; see AI acceptable use policy

8.3 Restricted uses (board approval required)

IDRestricted useCondition
RST-01Any use case in an AI Act Annex III area (for example employment, education, access to essential services, credit, insurance, law enforcement, migration, justice, critical infrastructure)Board approval, impact assessment and, for deployers in scope, a fundamental rights impact assessment
RST-02AI that makes or materially shapes decisions about individualsDocumented human review and a contest route
RST-03Training or fine-tuning on personal or customer dataDPIA, data owner approval, contract check
RST-04Autonomous agents that can act in external systems (payments, email, production changes)Tool permission design, human approval for high-impact actions, red team test
RST-05Public-facing generated content at scaleContent transparency plan and marking where required

9. Risk and impact assessment

Every AI system in scope goes through these steps before deployment and on any material change:

RequirementApplies toApproverRefresh
Use case intake and risk tierAll AI systemsAIMS managerOn material change
AI risk assessmentMedium and high tierBusiness owner; board for high tier[Annually] and on change
AI system impact assessmentSystems affecting individuals, groups or societyBusiness owner and board[Annually] and on change
Generative AI risk profileSystems using generative modelsTechnical ownerEach major release
DPIAProcessing likely to result in high risk to individualsDPO opinionOn change
Fundamental rights impact assessmentDeployers within AI Act Article 27BoardBefore first use and on change

Risk scoring, tolerance and acceptance authority follow the risk methodology [RISK-METH-001].

10. AI system life cycle

For each AI system the technical owner makes sure that:

  • requirements, including performance, safety and fairness acceptance criteria, are documented before development starts;
  • design decisions, data, models, prompts and evaluation results are recorded and version-controlled;
  • verification and validation results meet the acceptance criteria before release, and a launch review records the decision;
  • event logs are kept at least while the system is in use, with the retention period set in the logging standard;
  • operation is monitored for performance, drift, misuse and incidents, with a documented rollback or shutdown procedure;
  • technical documentation and user information are prepared for each audience that needs them;
  • retirement is planned, including data and model disposal.

11. Data for AI systems

  • Data used to train, fine-tune, evaluate or ground AI systems has a documented source, licence or lawful basis, and an owner.
  • Data quality criteria are defined per use and checked before use.
  • Provenance is recorded so the organisation can answer what data a model was built with and where it came from.
  • Personal data is minimised, pseudonymised where possible, and processed under the privacy policy and DPIA.
  • Customer data is used for AI training only when the contract allows it and the customer has been informed as agreed.

12. Third parties and customers

  • Responsibilities between the organisation, suppliers, partners and customers are allocated in writing for each AI system.
  • AI suppliers, including providers of general-purpose AI models, are assessed with the AI vendor risk questionnaire before contract and on renewal.
  • Contracts include, as relevant: data use limits, security, incident and change notification, audit or evidence rights, documentation, model change notice, AI Act cooperation duties and exit support.
  • Before rebranding, substantially modifying or repurposing a third-party AI system, legal reviews whether the change makes the organisation a provider under AI Act Article 25.
  • Customer requirements and expectations for AI are captured and reflected in product decisions and documentation.

13. Transparency and information

  • People are informed when they interact directly with an AI system, unless this is obvious from the context.
  • Synthetic audio, image, video or text content is marked or disclosed where the law requires it, following the content transparency plan.
  • User documentation states the intended purpose, known limitations and how to report problems.
  • A summary of this policy is published for interested parties [location].

14. Human oversight

LevelDescriptionTypical use
Human in the loopA person approves each output before it takes effectDecisions about individuals, external communications in regulated areas
Human on the loopA person monitors and can intervene or stop the systemAgents acting within limited permissions, fraud alerts
Human in commandPeople set goals and limits and review aggregate performanceLow-risk automation, internal analytics

Staff assigned to oversight have the competence, authority and time to do it, and can override or stop the system without penalty.

15. Incidents and concerns

  • Anyone can raise a concern about an AI system through [channel], with protection against retaliation under the speak-up policy.
  • AI incidents and near misses (for example harmful outputs, data exposure, discriminatory results, unsafe actions by an agent) are reported to [[email protected]] and handled under the AI incident response plan.
  • The incident manager assesses legal and contractual notification duties for each incident and records the decision.
  • Lessons learned feed the risk register and the Statement of Applicability.

16. Competence, awareness and AI literacy

  • The policy is communicated to all staff at onboarding and after each revision, and acknowledgement is recorded.
  • Role-based AI literacy measures follow the AI literacy plan and take into account people's knowledge, experience and the context of use.
  • People with AI governance, development, oversight or audit roles have documented competence, refreshed at least [annually].

17. Exceptions

Requests for an exception to this policy are submitted to the AIMS manager with the business reason, the risk, compensating measures and the end date. The AI governance board decides. Exceptions are recorded in the exceptions register, last no longer than [12 months] and are reviewed before renewal. No exception can be granted for a practice prohibited by law.

Exception IDSectionReasonCompensating measuresApproved byExpires
EXC-AI-001 (Example)11 (customer data for training)Pilot with anonymised tickets from one consenting customerContract addendum, DPIA, deletion after pilot[@ai-governance-board]YYYY-MM-DD

18. Compliance and monitoring

  • The AIMS manager reports AIMS performance, objective status, incidents and audit results to top management at least [twice a year].
  • Internal audit covers this policy within the AIMS audit programme.
  • Breaches are handled under the disciplinary or contractual process and are recorded as nonconformities with corrective action (clause 10.2).

19. Policy review

The owner reviews this policy at least [annually] and also when: a new AI law or major amendment applies to the organisation; the organisation takes on a new AI role (for example becomes a provider); a serious AI incident occurs; management review or audit finds the policy ineffective; or the business strategy for AI changes. Each review is recorded in the revision history, even when no change is made.

20. Related documents

DocumentRelationship
AI acceptable use policy (ai-data/ai-usage-policy)Staff rules for using AI tools; implements section 8 for individuals
Statement of Applicability (ISO/IEC 42001)Controls selected to implement this policy
AI management system policy and impact assessmentShort combined policy and impact format for smaller organisations
AI use case intake (ai-data/ai-use-case-intake)Entry point for section 8 and 9 decisions
AI risk assessment (ai-data/ai-risk-assessment)Method for section 9
AI system impact assessment (ai-data/ai-impact-assessment-42005)Method for section 9
AI literacy plan (ai-data/ai-literacy-plan)Implements section 16
AI vendor risk questionnaireImplements section 12
Objectives registerHolds AI objectives under section 6
Information security policy, privacy policy, procurement policyExample: Updated to reference AI threats, AI data use and AI supplier checks

21. Glossary and references

TermMeaning
AI systemMachine-based system that infers from input how to generate outputs such as predictions, content, recommendations or decisions
AIMSAI management system under ISO/IEC 42001
ProviderOrganisation that develops an AI system or model and places it on the market or puts it into service under its own name
DeployerOrganisation using an AI system under its authority in a professional activity
General-purpose AI modelModel trained on broad data that can perform a wide range of tasks and be integrated into many systems
Impact assessmentAssessment of the potential consequences of an AI system for individuals, groups and society

References: ISO/IEC 42001:2023, clauses 5.2, 5.3, 6.1, 6.2, 7.2, 7.3, 9, 10 and Annex A (A.2 to A.10), Annex C; Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744 (consolidated text on EUR-Lex), Articles 4, 5, 14, 25, 26, 27, 50, 73 and Annex III; NIST AI RMF 1.0; ISO/IEC 42005:2025.

Standard and licence note

Structure aligned with ISO/IEC 42001:2023, clauses 5.2, 5.3 and 6.2 and Annex A control objective A.2. ISO/IEC standards are copyrighted: this template cites clause and control numbers only, and all policy text is original; obtain the standard for the normative requirements and check the current edition. The prohibited practices are summarised in original wording from Article 5 of Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744; EU legislative texts are free to reuse. Check the consolidated text on EUR-Lex for binding wording and application dates. This is a documentation format, not legal advice. Template licence: MIT.

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