A Phased Approach to AI Governance
Published on by Robert Ramsay in SOC Reports, Assurance
- AI governance doesn’t have to happen all at once. A phased approach makes compliance manageable while building toward a mature program.
- Your SOC 2 report can provide the foundation. Existing controls can be expanded to address AI governance without starting from scratch.
- Each phase builds on the last. Start with AI inventory, risk assessment, and accountability, then add active controls and continuous monitoring.
- ISO 42001 and NIST can work together. An integrated approach can address multiple stakeholder expectations without creating separate compliance programs.
- Start with what makes sense for your organization. A readiness assessment can identify the smallest realistic first step and a roadmap for what comes next.
Why AI governance can’t wait…but doesn’t have to happen all at once
Clients and prospects are asking how AI shows up in your products and services: what data it touches, who’s accountable, and what happens when something goes wrong. A SOC 2 report answers many important questions. A SOC 2 with ISO 42001 answers even more.
ISO 42001 is the international standard built specifically for managing artificial intelligence (AI): covering the ethics, transparency, accountability, and risk management that a growing number of your stakeholders expect to see in writing.
A common response is to treat that as a second, separate project with a new framework, a new audit, a new lift for your team. But it doesn’t have to be. If you already have a SOC 2 report, you already have the infrastructure AI governance builds upon.
More importantly, most organizations don’t need a brand-new AI governance program in year one. Rather, it’s about taking the right steps at the right time.
We can leverage your annual SOC 2 audit to grow your compliance program to show clients and regulators you’re managing AI responsibly.
Baseline: Your SOC 2 report today
Security and availability controls, audited annually, the way it’s always worked. Nothing changes yet. This is your starting point.
Year 1: Lay the foundation
A focused first step: inventory the AI systems you’re using, identify and prioritize risks, and assign oversight roles. Expand existing policies where appropriate to include AI coverage. This shows up as a disclosure-level addition to your report. You’re documenting what exists and who owns it, without a testing burden on top of it.
Year 2: Add live action controls
Once the foundation is in place, we expand into active risk controls: model monitoring and due diligence on your AI vendors. This is where testing comes in—a manageable, incremental piece, not a wholesale redo of your audit.
Year 3: Full integration
AI governance is no longer an add-on subsection of your report. It’s built into continuous monitoring and mapped to both ISO 42001 and the NIST AI Risk Management Framework. You’re not just compliant: you have a credible, audit-backed answer for anyone who asks how you manage AI.
Each stage is right-sized for your situation and builds directly on the last. Nothing you do in Year 1 gets thrown out in Year 3.
Wherever you’re starting from, there’s a path in
Already have a SOC 2 report?
You’re closer than you think. AI governance builds directly onto the report you produce every year—no separate audit, no starting over. We’ll assess what you’re already doing with AI, and scope the smallest first step that gets you a credible ISO 42001-aligned story.
New to SOC 2, but you need ISO 42001?
Start with the foundation. We’ll help you establish the SOC 2 controls that ISO 42001 governance builds on, so you’re not managing two disconnected frameworks; you’re building one program that does both.
Barnes Dennig can meet you where you are and take you where you need to go
We’ve guided clients through this exact transition, and adoption has been strong enough that we’re confident recommending it as the default path, not a pilot.
We work in both major frameworks (ISO 42001 and NIST), so your report can speak to international and U.S. government-aligned expectations without maintaining two separate compliance efforts.
Ready to see where you’d start?
Every organization’s AI footprint looks different, so your Year 1 will, too. Talk to our SOC Reporting team about a readiness assessment—we’ll help you find the smallest realistic first step and build the roadmap from there.
Schedule your readiness assessment today.
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You might also be interested in our SOC Reporting FAQ, packed with answers to the questions our SOC pros hear most often, or in our SOC reporting Ask the Experts series, available on our YouTube channel. Finally, our free SOC Reporting Toolkit can help you get the most from your SOC auditing experience, streamlining the process and reducing costs.
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