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A.6 AI system life cycle
ISO 42001A.6.2.2

ISO 42001 Annex A 6.2.2 AI system requirements and specification

What it says

The organization shall specify and document requirements for new AI systems or material enhancements to existing systems.

Quoted as published. Everything else on this page is written by Control Stack.

What it means

In plain English

Before building a new AI system or materially changing an existing one, write down exactly what it must do and what it must not do, and keep that specification on file.

When you start a new AI project or make a big change to one you already run, this control says you must write down what the system needs to deliver before work begins. That means setting out, in a document, the tasks it has to perform, how accurate it needs to be, what data it can use, and the privacy, safety and fairness limits it must respect. A material enhancement (a change big enough to alter how the system behaves or who it affects) triggers the same step, so the written requirements are revisited rather than left frozen at version one.

Why it matters

Without a written requirements specification, teams build or buy AI against assumptions that were never agreed, and a gap such as an unstated accuracy floor or an unstated rule against using a special-category data field is only discovered after the system is live and a wrong decision has already affected real people. A recruitment-screening or benefits-eligibility model can quietly fall short of an accuracy or fairness need that nobody documented, producing a cohort of incorrectly rejected applicants and a possible OAIC privacy complaint once individuals learn their data drove an automated outcome they were never told about. Fixing it after deployment usually means withdrawing the system and rebuilding from scratch.

How to implement

  1. Bring the people who will actually use the system together with the team that will build or buy it, and write down what the system has to achieve before any development or purchase starts; capturing those needs as a short numbered list keeps them testable later.

  2. Make sure the specification covers more than features: have the person responsible for the AI system record the accuracy or quality the model must reach, the data sources it is allowed to use, and the privacy, safety and fairness limits it must stay within, since these non-functional needs are what usually get missed.

  3. Treat any material enhancement as a reason to reopen the document.

    When someone raises a significant change request, the project owner should revisit the requirements, mark what has changed, and have the new version approved rather than letting the old one stand.

  4. Write each requirement so it can be checked, and have whoever leads testing tie every requirement to an acceptance criterion, so a missed accuracy or privacy need is caught before the system goes live instead of after.

  5. Where a requirement cannot be met, the system owner should record the gap and the decision taken instead of quietly dropping it, so the trade-off stays visible to whoever later approves the system for use.

Keep it running

Keep the requirements for each AI system in a versioned baseline (a requirements register) so you can see what was agreed and when it changed. Treat every material enhancement or significant change request as a trigger to reopen that baseline, re-validate the functional needs (what the system must do) and the non-functional needs (accuracy targets, latency, security, privacy and fairness limits), and record who signed off the new version. Where a requirement cannot be met, note the gap and the decision taken rather than deleting it, so the trade-off is traceable. Link each requirement to the test or acceptance check that will later prove it was satisfied.

Evidence and audit

  1. Check 1 of 5What an auditor asks for

    Ask for

    Ask for the written requirements specification for the most recently started or most recently changed AI system.

    Look at

    Whether it sets out both what the system must do and non-functional limits such as a stated accuracy target, permitted data sources, and privacy or fairness constraints, not just a feature wish-list.

    Good evidence

    The specification names concrete functional and non-functional requirements, carries a version number, and is signed off by a named owner before build or procurement began.

  2. Check 2 of 5What an auditor asks for

    Ask for

    Ask for the change or enhancement record for a material change made to an existing AI system in the last year.

    Look at

    Whether the original requirements were reopened and revised for that change rather than the change going ahead against the version-one document.

    Good evidence

    The record links to a dated, revised requirements version that reflects the enhancement and shows fresh approval.

  3. Check 3 of 5What an auditor asks for

    Ask for

    Ask the person who owns the AI system to show how each requirement will be confirmed as met.

    Look at

    Whether requirements are tied to acceptance criteria or tests, so an unmet requirement would be caught before go-live.

    Good evidence

    Each documented requirement maps to an acceptance check or test case, and any requirement that could not be met is recorded with the decision taken.

  4. Check 4 of 5What an auditor asks for

    Ask for

    Ask for the requirements register or baseline covering AI systems in scope.

    Look at

    Whether every in-scope new system and material enhancement has a current documented requirements entry, or whether some systems have none.

    Good evidence

    The register lists each in-scope system with a current, versioned requirements document and no live system is missing one.

  5. Check 5 of 5What an auditor asks for

    Ask for

    Ask for the constraints recorded for a customer-facing or decision-making AI system.

    Look at

    Whether the document states data the system may not use and decisions it must not make without human review.

    Good evidence

    The specification records explicit prohibitions and human-review points, showing privacy and safety limits were specified up front, not added later.

Mappings

Closest match in ISO/IEC 27001: A.5.8, Information security in project management, which partially overlaps with this control.

ISO 27001

ISO/IEC 27001: 2 mappings

ASD ISM

ASD Information Security Manual: 4 mappings

Mappings show how controls relate across frameworks. They do not imply full equivalence or certification.

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ISO 42001 training

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