✅ ISO 42001:2023 – AI Governance & Compliance Audit

Checklist
 AI Audit Checklist

AI Governance & Compliance Checklist

Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Review governance
Does the organization have a
documents, policies, and
documented AI governance
roles related to AI
framework?
governance.
Are AI risk management Assess AI risk management
AI Governance Policies processes aligned with ISO documentation and compare
42001, NIST AI RMF, and against ISO, NIST, and GDPR
GDPR? standards.
Check meeting minutes,
Is there an AI ethics
structure, and decision-
committee overseeing AI
making authority of the AI
governance?
ethics committee.
Does the AI system comply
Review legal compliance
with GDPR, ISO 42001, CCPA,
documentation and
or sector-specific
regulatory audit reports.
regulations?
Are AI data processing Examine data processing
Regulatory Compliance
activities documented and policies, logs, and legal bases
legally justified? for AI data use.
Are AI models designed to Review AI system
ensure transparency, documentation, model
explainability, and explanations, and
accountability? accountability mechanisms.
Is there a risk assessment Evaluate risk assessment
framework for AI frameworks, methodologies,
deployment? and past risk reports.
Check AI risk reports,
AI Risk Management & Are AI risks monitored and
monitoring dashboards, and
Auditing reported regularly?
periodic risk assessments.
Review AI audit policies, past
Does the organization have a audit reports, and
formal AI audit plan? compliance review
schedules.

AI Bias Detection & Fairness Auditing Checklist

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 AI Audit Checklist
Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Is AI training data diverse Review dataset composition,
and representative of demographic distributions,
different demographics? and data collection sources.
Has the AI model been Analyze bias testing reports,
tested for racial, gender, orfairness analysis results, and
socioeconomic biases? past bias mitigation efforts.
AI Training Data Bias
Are fairness metrics such as Check if fairness metrics are
Assessment
Equalized Odds, calculated and if disparities
Disparate Impact, and are flagged for corrective
Statistical Parity applied? action.
Review preprocessing
Are data preprocessing
methodologies like data
techniques used to remove
balancing, re-weighting, or
historical biases?
adversarial debiasing.
Does the AI model undergo Examine AI audit reports and
regular bias audits and fairness testing logs for
fairness testing? evidence of regular
monitoring.
Review fairness
Are fairness results
documentation, compliance
documented and reviewed
reports, and stakeholder
AI Model Fairness & by compliance teams?
reviews.
Transparency
Assess whether AI models
Does AI have explainability
are equipped with SHAP,
tools (SHAP, LIME) to clarify
LIME, or other explainability
decisions?
tools.
Check if AI models have
Is AI fairness validated using
been tested with IBM AI
external tools like IBM AI
Fairness 360, Fair learn, or
Fairness 360, Fairlearn?
similar frameworks.
Are AI-generated decisions Review AI decision audit logs
audited for fairness before and pre-deployment
AI Decision Review & Human
deployment? validation reports.
Oversight
Is there a human-in-the-loop Examine human oversight
process to monitor AI mechanisms, workflows, and
decisions? monitoring procedures.

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 AI Audit Checklist
Are users given the ability
to challenge AI decisions in Verify if appeal mechanisms
high-risk applications (e.g., exist for AIgenerated
hiring, lending, law decisions in high-risk areas.
enforcement)?

AI Security & Adversarial Attack Protection Checklist

Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Are AI models protected Review access control
with role-based access policies and verify
control (RBAC)? implementation of RBAC.
Does the AI system require Check authentication
multi-factor authentication configurations and system
AI Model Security & Access
(MFA) for access? logs for MFA enforcement.
Controls
Are AI models encrypted at Review encryption policies
rest and in transit (e.g., AES- and test encryption of stored
256, TLS 1.3)? and transmitted AI data.
Is there logging and Examine AI system access
monitoring of AI access logs and monitoring
attempts? dashboards.
Are AI models tested against
Analyze adversarial
adversarial attacks (evasion,
robustness testing reports
poisoning, model inversion,
and security evaluations.
etc.)?
Are AI training datasets Review dataset protection
protected against data measures and security
poisoning attacks? policies against poisoning
Adversarial Attack & AI Model attacks.
Tampering Protection Has AI undergone
penetration testing using Examine penetration testing
adversarial AI security tools reports and security
(e.g., Microsoft Counter fit, assessments.
Clever Hans)?
Monitor AI model behavior
Is AI output monitored for
logs and validate unexpected
unexpected behavior caused
output detection
by adversarial inputs?
mechanisms.

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 AI Audit Checklist
Review API authentication
Are AI APIs secured with
mechanisms, security
OAuth 2.0 authentication
tokens, and rate-limiting
and rate limiting?
configurations.
Does AI use API monitoring Analyze API monitoring
and anomaly detection to reports and anomaly
prevent unauthorized detection logs.
AI API & Cloud Security queries?
Measures Are AI model weights and
datasets secured in cloud Check cloud security
environments (AWS, Azure, configurations, encryption
Google Cloud) with settings, and access control
encryption and restricted policies.
access?
Does AI security comply with Review cybersecurity audit
ISO 27001, SOC 2, and NIST reports and compliance
Cybersecurity Framework? documentation.
AI Explainability & Transparency Auditing Checklist
Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Is AI model documentation Review AI model
comprehensive and documentation, system
accessible for auditors? design, and training logs.
Does AI provide clear Analyze model explainability
explanations for reports and decisionmaking
decisionmaking processes? justifications.
AI Model Interpretability &
Are AI model parameters, Check documentation of
Documentation
assumptions, and feature model parameters, key
importance well- assumptions, and feature
documented? importance analysis.
Are explainability
Examine whether SHAP,
frameworks (e.g., SHAP,
LIME, or similar frameworks
LIME, Integrated Gradients)
are used for interpretability.
used?
Review compliance policies,
User & Regulatory Does the AI system comply
GDPR documentation, and
Explainability Requirements with GDPR’s 'Right to
'Right to Explanation'
Explanation'?
implementation.

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 AI Audit Checklist
Conduct user surveys or
Can end-users understand
tests to evaluate the
AI-generated decisions (e.g.,
understandability of AI
loan approvals, hiring)?
decisions.
Is there an explainability Assess the presence and
dashboard for auditors and functionality of an
compliance teams? explainability dashboard.
Are AI-generated Review AI justification logs,
justifications consistent, decision consistency tests,
unbiased, and reproducible? and bias assessments.
Is AI trained on open-source, Examine dataset licenses,
legally obtained, and sourcing records, and ethical
AI Transparency & Ethical
ethically sourced data? data acquisition reports.
Compliance
Are AI decision pathways Check audit logs and
logged and traceable for traceability mechanisms for
compliance audits? AI decision pathways.

Review disclosures in user

Does AI disclose when a
interfaces and decision
decision is AI-generated vs.
reports regarding AI-
AI Transparency & Ethical human-generated?
generated outcomes.
Compliance
Are transparency guidelines Analyze AI transparency
aligned with ISO 42001, EU documentation and
AI Act, and OECD AI alignment with regulatory
Principles? guidelines.
AI Model Performance & Drift Monitoring Checklist
Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Does AI undergo regular Review AI testing reports,
accuracy testing using confusion matrices, and
AI Model Accuracy & Stability
precision, recall, F1-score, performance metric
Checks
and AUC-ROC? calculations.
AI Model Accuracy & Stability
Are AI models validated Analyze AI validation reports
Checks
against real-world datasets using real-world datasets to
AI Model Accuracy & Stability
to prevent overfitting? detect overfitting risks.
Checks
Is AI performance tracked
AI Model Accuracy & Stability Check AI performance
over time using trend
Checks dashboards and statistical
analysis and performance
trend analysis reports.
metrics?
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Are AI models tested under Examine test cases,
different conditions and adversarial scenarios, and
edge cases? edge case testing results.
Does AI have automated
Review AI drift detection
drift detection to identify
logs and automated
model performance
monitoring alerts.
degradation?
Are AI predictions compared Compare AI predictions
to real-world outcomes to against real-world outcomes
Model Drift & Continuous
detect drift? and historical benchmarks.
Monitoring
Is there a retraining schedule Examine AI retraining logs
to update AI models with and schedule adherence.
fresh data?
Are AI monitoring tools (e.g.,
Verify implementation of AI
Evidently AI, AWS Model
monitoring tools and their
Monitor, Azure ML
alert configurations.
Monitoring) used?
Is there a formal AI model Review AI model retraining
retraining and validation policies, guidelines, and
policy? governance documentation.
Are AI updates and Assess AI update logs,
retraining logged and compliance team meeting
reviewed by compliance records, and retraining
AI Model Retraining & teams? validation reports.
Governance Check if auditors have
Are auditors provided with
unrestricted access to AI
historical AI performance
performance logs and
reports for assessment?
reports.
Does AI comply with ISO Review compliance
42001 and NIST AI RMF documentation for
guidelines on model lifecycle adherence to ISO 42001 and
management? NIST AI RMF requirements.
AI Deployment & Post-Implementation Risk
Auditing Checklist

Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
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 AI Audit Checklist
Are AI deployment
Review AI deployment
environments protected
security policies and access
against unauthorized
logs.
modifications?
Are role-based access Assess RBAC policies and
controls (RBAC) user role configurations for
AI Deployment Security & implemented to restrict AI AI system changes.
Governance model changes?
Is AI deployment aligned Check compliance
with cloud security documentation and audit
standards (ISO 27001, SOC 2, reports for cloud security
NIST CSF)? adherence.
Are AI models encrypted at Analyze encryption policies
rest and in transit to prevent and validate implementation
data leaks? in AI deployment.
Inspect AI monitoring
Is AI performance tracked
dashboards, logs, and
using real-time monitoring
performance tracking
dashboards?
systems.
AI Model Post- Are AI-generated decisions Review AI decision logs for
Implementation Monitoring logged and reviewed for unusual patterns and
anomalies? conduct anomaly detection
tests.
Is AI monitored for bias Analyze AI bias monitoring
reintroduction or model drift reports and model drift
over time? analysis logs.

Are AI post-deployment Check AI audit submission

AI Model Post- reports regularly submitted records and compliance
Implementation Monitoring to auditors and compliance team reviews.
teams?
Are there predefined AI Examine AI incident
failure response protocols in response plans and failure
case of system errors? protocol documents.
Is there a rollback Review rollback process
AI Incident Response & Fail-
mechanism to revert AI documentation and conduct
Safe Mechanisms
models to previous stable rollback testing if feasible.
AI Incident Response & Fail-
versions?
Safe Mechanisms
Verify AI security alert
Are AI alerts integrated into
configurations and
security teams for real-time
integration with SOC/SIEM
anomaly detection?
tools.
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 AI Audit Checklist
Does AI have a 'human-in- Evaluate human intervention
the-loop' intervention mechanisms and case
system for high-risk studies for AI-assisted
applications? decision-making.
AI Ethical Compliance & Responsible AI Auditing Checklist
Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Does the organization follow
responsible AI frameworks Review AI governance
(OECD AI Principles, UNESCO policies and adherence to
AI Ethics, ISO 42001, EU AI responsible AI frameworks.
Act)?
Are AI models designed with Examine AI model design
fairness, accountability, and documentation for fairness,
AI Ethical Guidelines &
transparency (FAT) accountability, and
Compliance
principles? transparency principles.
Is AI decision-making aligned Analyze AI decision-making
with corporate ethics and policies and ethical
human rights guidelines? compliance guidelines.
Review impact assessments
Are AI-generated outcomes
and audits of AIgenerated
reviewed for unintended
outcomes for unintended
negative consequences?
harm.
Is there a human-in-the-loop Check documentation on
(HITL) or human-onthe-loop human oversight
(HOTL) mechanism for AI mechanisms and HITL/HOTL
decisions? implementations.
Can end-users challenge and Verify user appeal processes
Human Oversight & AI appeal AIgenerated and mechanisms for
Accountability decisions? challenging AI decisions.
Are AI risks communicated Assess stakeholder
to stakeholders and communication reports and
regulators? AI risk disclosure statements.
Is there a clear escalation Examine AI failure escalation
process for AI failures or workflows and historical
ethical concerns? incident reports.
AI Bias, Inclusivity, and Does AI undergo bias and Review AI bias and fairness
Fairness Audits fairness testing before testing reports and
deployment? validation processes.
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 AI Audit Checklist
Are AI datasets diverse and Analyze AI dataset
representative of all user composition and diversity
groups? assessment reports.
Is there external third-party Check external audit reports
auditing of AI fairness and and fairness compliance
inclusivity? certifications.
Does AI comply with GDPR's
Evaluate GDPR, AI Act, and
Right to Explanation, AI Act
anti-discrimination
risk classification, and anti-
compliance documentation.
discrimination laws?
AI Continuous Monitoring & Automated Risk
Detection Checklist
Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Is AI performance tracked
Inspect AI monitoring
using real-time dashboards
dashboards and logs for real-
and anomaly detection
time performance tracking.
tools?
Are AI risks automatically
Review AI risk detection
flagged using machine
reports and logs from
learning-based auditing
automated auditing systems.
AI Real-Time Monitoring & systems?
Alert Systems Are AI models integrated
with SIEM (Security Check AI security integration
Information and Event with SIEM platforms and
Management) tools for security monitoring logs.
security monitoring?
Are automated alerts sent to
Analyze AI security alert
compliance and security
configurations and response
teams for quick
protocols.
remediation?
Are AI bias detection tools
Assess AI bias monitoring
AI Bias & Drift Detection (e.g., IBM AI Fairness 360,
tool integration and review
Automation Fairlearn) integrated for
bias detection reports.
continuous auditing?

Does AI automatically flag Review AI drift detection

AI Bias & Drift Detection
model drift and degradation mechanisms and retraining
Automation
for retraining? triggers.
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AI Bias & Drift Detection Are fairness checks Examine automated fairness
Automation performed regularly with audit reports and
automated reports? compliance tracking logs.
Are baseline fairness metrics Review baseline fairness
defined for AI compliance metric definitions and
tracking? implementation evidence.
Does AI monitoring include Analyze AI security logs and
intrusion detection for verify intrusion detection
adversarial attacks? effectiveness.
Are AI-generated logs Review AI system logs and
reviewed for anomalies that identify anomalies that may
may indicate cyber threats? indicate security risks.
AI Security & Adversarial Are adversarial attack
Attack Detection detection tools (e.g., Check AI security policies
Microsoft Counterfit, and adversarial attack
CleverHans) integrated into defense mechanisms.
AI security frameworks?
Is there an automated
Verify AI rollback
rollback or shutdown
mechanisms and assess past
mechanism in case of AI
rollback or shutdown cases.
failures?
Does AI undergo automated Review AI compliance
compliance checks against automation reports and
GDPR, ISO 42001, EU AI Act, audit history for GDPR, ISO,
NIST AI RMF? and AI Act alignment.
Inspect AI-generated
Are AI-generated decisions
decision logs and confirm
AI Continuous Compliance automatically logged and
they meet transparency
Monitoring audited for transparency?
requirements.
Are AI compliance reports Assess AI compliance report
generated in real-time for generation frequency and
regulatory audits? content.
Does AI alert governance Check AI governance alert
teams if compliance mechanisms and review past
thresholds are breached? compliance alerts.
AI Audit Report Writing & Documentation Best
Practices Checklist
Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
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 AI Audit Checklist
Does the report include a Review AI audit reports for
clear executive summary completeness and clarity of
with key findings? the executive summary.
Are AI risks categorized Analyze risk categorization
based on impact level (low,methodologies in AI audit
medium, high, critical)? reports.
AI Audit Report Structure &
Are all audit findings Validate if audit findings
Documentation
supported with data, include supporting data,
evidence, and analysis? evidence, and in-depth
analysis.
Is there a recommendation Check the presence and
section outlining corrective structure of the corrective
actions? action recommendations
section.
Does the audit report Examine AI audit
include AI model compliance documentation for
status (GDPR, ISO 42001, compliance status across
NIST AI RMF, AI Act)? major regulatory standards.
Are AI governance policies Assess AI governance
and procedures properly documentation for
documented? completeness and policy
AI Governance & Compliance
adherence.
Documentation
Is AI decision-making Review AI decision-making
transparency clearly transparency logs and
explained with logs and justifications included in the
model justifications? report.
Are compliance gaps and Inspect compliance reports
regulatory concerns for regulatory gaps and
highlighted with mitigation proposed mitigation
plans? strategies.
Does the report include bias Analyze bias and fairness
and fairness assessment testing documentation
results? included in the audit report.
Are AI performance metrics Compare AI performance
AI Bias, Fairness, and
compared against baseline benchmarks to established
Performance Reporting
standards? baseline standards.
Is AI drift detection
documented with trend Review AI drift detection
analysis and remediation logs and trend analysis data.
steps?

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 AI Audit Checklist
Are fairness audit results Inspect audit reports for
visualized using charts and fairness results visualized
statistical summaries? with statistical summaries.
Does the report include Assess security audit logs for
security vulnerabilities, vulnerability testing,
AI Security & Risk adversarial risks, and attack adversarial risk analysis, and
Management Reporting simulations? simulations.
Are AI security incidents Review AI security incident
logged and analyzed for logs and impact analysis
impact assessment? reports.
Compliance
Status
Audit Area Audit Question How to Check
(Yes/No) &
Remarks
Check if AI security and
Are security and compliance
compliance gaps are
gaps mapped to regulatory
mapped to relevant
AI Security & Risk frameworks?
frameworks.
Management Reporting
Are recommendations for Validate the security
security improvements recommendations section
clearly outlined with action for clear and actionable
plans? remediation steps.
Is there a post-audit follow- Examine follow-up plans for
up plan for reviewing AI tracking AI improvements
improvements? post-audit.
Are AI audit results tracked Assess AI governance
over time to monitor monitoring records to
governance improvements? ensure long-term tracking of
AI Continuous Monitoring & audit results.
Post-Audit Follow-Up Are continuous AI
Review automated
compliance assessments
compliance tracking tools for
scheduled with automated
AI risk assessment.
tracking?
Are AI audit stakeholders Check if AI risk and
provided with regular governance reports are
reports on AI risks and distributed regularly to
governance updates? stakeholders.

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