ISO 42001 Annex A 3.2 Define and allocate AI roles and responsibilities
What it says
Roles and responsibilities for AI shall be defined and allocated according to the needs of the organization.
Quoted as published. Everything else on this page is written by Control Stack.
What it means
In plain EnglishYour organisation must clearly decide who is responsible for each part of managing artificial intelligence and formally assign those responsibilities to named people.
Artificial intelligence (AI) does not manage itself. Someone has to decide which tools to use, check they are safe and fair, keep an eye on how they behave, and step in when something goes wrong. This control says your organisation must work out exactly what jobs need doing to manage AI responsibly, and then give each of those jobs to a specific person or team so nothing falls through the cracks. Think of it like running a kitchen. You need someone ordering ingredients, someone cooking, someone checking the food is safe to serve, and someone in charge overall. If nobody is clearly assigned to each task, mistakes happen and no one knows whose fault it is. The same is true for AI: roles such as who approves new AI tools, who monitors them, and who answers customer or regulator questions all need a clear owner. The roles you create should fit the size and needs of your organisation. A small business might give several AI duties to one or two people, while a larger organisation might need a dedicated team. The key is that responsibilities are written down, allocated to real people, and understood by everyone involved.
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Why it matters
If AI roles are unclear, no one owns key decisions, problems go unnoticed, and accountability gaps can lead to harm, breaches, or regulatory failure.
How to implement
Senior management lists every task needed to manage artificial intelligence (AI) safely, such as approving new AI tools, monitoring performance, handling complaints, and reporting to the board, then writes each one into a simple roles document.
The AI management lead assigns each listed responsibility to a named person or team and records this in role descriptions or job descriptions, so every duty has a clear owner rather than being left to chance.
Human resources updates the position descriptions or employment contracts of staff who carry AI duties, making the AI responsibilities an official part of their role rather than an informal add-on.
The AI management lead holds a short briefing with each person assigned an AI role so they understand what is expected of them, who they report to, and where their authority begins and ends.
Senior management reviews the allocation of AI roles at least once a year, or whenever the organisation adopts new AI tools or restructures, and reassigns duties so no responsibility is left without an owner.
Keep it running
Keep one source of truth for AI role allocations and update it whenever staff change or new AI tools are adopted, so duties never lapse unowned.
Evidence and audit
- Check 1 of 5What an auditor asks for
Ask for
a document or chart that lists the artificial intelligence (AI) roles and responsibilities across the organisation.
Good evidence
version names specific people or teams against each AI duty rather than vague references to a department.
- Check 2 of 5What an auditor asks for
Look at
the job descriptions or role descriptions of staff named as AI owners. Good evidence shows the AI responsibilities written explicitly into those descriptions, not just mentioned verbally.
- Check 3 of 5What an auditor asks for
Ask for
how responsibilities were decided and whether they match the size and needs of the organisation.
Good evidence
shows the allocation was deliberate and proportionate, not copied blindly from a template.
- Check 4 of 5What an auditor asks for
Look at
evidence that the assigned people know their AI responsibilities, such as briefing notes, training records, or meeting minutes. Good evidence shows the people named can describe their own duties when asked.
- Check 5 of 5What an auditor asks for
Ask for
when the role allocation was last reviewed and updated. Good practice is a review at least annually and after any major change, such as adopting a new AI tool, with records showing duties were reassigned where needed.
Mappings
Closest match in ASD Essentials for enterprise IT: IT.GOV-08.1, Name an executive accountable for AI use, governance and risk management, which this control covers in full and more.
ISO/IEC 27001: 2 mappings
This control partially overlaps A.5.2.
Annex A 3.2 (ISO/IEC 42001:2023) requires the organisation to define and allocate roles and responsibilities for AI. Annex A 5.2 (ISO/IEC 27001:2022) similarly requires defining and allocating information security roles and responsibilities, often including AI-related security accountabilities. Annex A 3.2 is broader for AI governance, while Annex A 5.2 is broader for information security.
This control partially overlaps A.5.24.
Annex A 3.2 requires defining and allocating AI roles and responsibilities. Annex A 5.24 (ISO/IEC 27001:2022) requires planning and preparing for incident management by defining and communicating roles and responsibilities. Both involve role assignment but Annex A 5.24 focuses on incident management, while Annex A 3.2 covers broader AI governance.
ASD Information Security Manual: 4 mappings
This control partially meets ISM-1997.
Annex A 3.2 requires defining and allocating roles and responsibilities for AI. ISM-1997 requires clear roles and responsibilities for cyber security. Annex A 3.2 is narrower as it focuses specifically on AI roles, while ISM-1997 covers organisation-wide cyber security roles.
This control partially overlaps ISM-0043.
Annex A 3.2 requires the organisation to define and allocate AI roles and responsibilities. ISM-0043 requires a cyber security incident response plan that explicitly defines reporting, responsible authorities for investigating/responding, and engagement with external agencies, which overlaps where AI systems are within the scope of cyber incidents and need clear accountability. ISM-0043 is incident-response specific and prescriptive, while Annex A 3.2 is broader AI governance and not limited to incident handling.
This control partially overlaps ISM-0717.
Annex A 3.2 requires AI roles and responsibilities to be defined broadly, while ISM-0717 mandates the CISO to oversee cyber security personnel, potentially including those focused on AI security. The overlap is in governance for AI when cyber security is involved, but Annex A 3.2 encompasses more than security roles.
This control supports ISM-1071.
Annex A 3.2 requires the organisation to define and allocate AI roles and responsibilities to meet organisational needs. ISM-1071 mandates that each system has a designated system owner, which supports AI role allocation by establishing a clear accountable owner for AI systems and their operation. ISM-1071 is narrower in that it focuses on a single accountable role (system owner), whereas Annex A 3.2 covers a fuller set of AI governance roles and responsibilities.
ASD Essentials for enterprise IT: 1 mapping
This control is broader than IT.GOV-08.1.
IT.GOV-08.1 requires the organisation to establish and maintain executive accountability for the use, governance and risk management of artificial intelligence. This is a specific instance of ISO/IEC 42001 Annex A 3.2, which requires roles and responsibilities for AI to be defined and allocated according to organisational needs. Annex A 3.2 covers all AI roles and responsibilities, whereas IT.GOV-08.1 addresses only accountability at the executive level.
Mappings show how controls relate across frameworks. They do not imply full equivalence or certification.
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