ISO 42001 Annex A 3.3 Process for reporting concerns about AI systems
What it says
The organization shall define and put in place a process to report concerns about the organization's role with respect to an AI system throughout its life cycle.
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What it means
In plain EnglishSet up a clear, accessible way for people to raise concerns about your organisation's role in any AI (artificial intelligence) system at any stage of its life.
This control asks your organisation to create a proper process so anyone (staff, contractors, customers or partners) can report concerns about the role your organisation plays with an AI (artificial intelligence) system. The concern could be about anything across the system's whole life cycle, from the idea and design stage, through building and testing, into day-to-day use, and finally retirement. Examples might be worries that an AI tool is producing unfair results, handling personal data badly, being used in a way that was not intended, or causing harm to people. The point is that problems with AI rarely announce themselves. The people closest to the work often notice something feels wrong long before it becomes a public failure. Without an agreed, well-known channel to speak up, those early warnings get lost. This control makes sure there is a defined route to raise a concern, someone responsible for receiving and acting on it, and confidence that raising a concern is welcomed rather than punished. It is a key part of running AI responsibly and supports your AIMS (AI management system).
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Why it matters
Without a reporting process, early warnings about an AI system go unheard, letting harm, unfair outcomes or breaches grow into serious failures.
How to implement
The AI management lead should create a written procedure that explains who can raise a concern about an AI system, what counts as a concern, how to submit it, who receives it, and what happens next once it is received.
Set up at least one easy-to-find reporting channel, for example a dedicated email address, an online form, or an item in your existing whistleblowing or incident tool, and make sure staff and relevant external parties know it exists.
Assign a named owner, such as a compliance manager or AI ethics officer, who is responsible for logging each concern, deciding how serious it is, and tracking it through to a resolution within agreed timeframes.
Make the process safe to use by allowing concerns to be raised confidentially or anonymously, and state clearly in policy that anyone raising a genuine concern in good faith will not face retaliation.
Cover the full life cycle by reminding teams during design reviews, testing, go-live and decommissioning that concerns can be raised at any of these stages, and record each concern, the action taken, and the outcome.
Keep it running
Monitor the reporting channel regularly, acknowledge each concern promptly, and review the concerns log periodically to spot recurring AI risks and trends.
Evidence and audit
- Check 1 of 2What an auditor asks for
Ask for
the documented procedure that defines how concerns about AI systems are reported, and check that it names who can report, the channels available, who receives concerns, and the steps for handling them.
Look at
the actual reporting channels (such as the email inbox, form, or tool) and confirm they are live, monitored, and known to staff rather than just described on paper.
- Check 2 of 2What an auditor asks for
Ask for
a log or register of concerns raised over the past year and check that each entry shows when it was received, who handled it, what action was taken, and how it was closed.
Look at
whether the process covers the whole AI life cycle and whether there is evidence concerns can be raised at design, development, operation and retirement, not only after something has gone wrong.
Good evidence
a clearly owned, well-publicised process with a real history of concerns being received and resolved, confidentiality and non-retaliation protections in place, and staff who can describe how they would raise a concern.
Mappings
Closest match in ISO/IEC 27001: A.6.8, Mechanisms for reporting security events, which partially overlaps with this control.
ISO/IEC 27001: 1 mapping
This control partially overlaps A.6.8.
Annex A 3.3 (ISO/IEC 42001) requires the organisation to implement an accessible process for reporting concerns about the organisation's role in an AI system across its life cycle. Annex A 6.8 (ISO/IEC 27001) similarly requires defined channels for personnel/parties to report security events and suspected weaknesses promptly, which can be used as part of the reporting pathway for AI-related concerns where they manifest as security events. However, Annex A 3.3 is broader in topic (ethical, safety, compliance, misuse, accountability concerns), while Annex A 6.8 is narrower and focused on information security events/weaknesses.
ASD Information Security Manual: 1 mapping
This control partially overlaps ISM-0043.
Annex A 3.3 (ISO/IEC 42001) requires a process for reporting concerns about the organisation’s role in AI systems across the AI life cycle. ISM-0043 requires incident response plans to define what constitutes an incident and how to report incidents internally and to relevant authorities, which overlaps with the escalation and reporting channels portion of an AI concerns process when the concern is cyber security-related (e.g. model compromise, data leakage). ISM-0043 is limited to cyber security incidents and evidentiary handling, while Annex A 3.3 also covers broader AI governance concerns that may not be incidents.
Mappings show how controls relate across frameworks. They do not imply full equivalence or certification.
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