AI Governance Library

ISO 42001 Checklist of Implementation Steps

A practical, step-by-step checklist outlining 18 actions required to design, implement, operate, and continuously improve an Artificial Intelligence Management System (AIMS) in line with ISO/IEC 42001, from management commitment to continual improvement.
ISO 42001 Checklist of Implementation Steps

⚡ Quick Summary

This document is a hands-on implementation guide for organizations aiming to operationalize ISO/IEC 42001. Rather than focusing on abstract principles, it translates the standard into 18 concrete steps that mirror the lifecycle of an AI Management System: planning, risk assessment, control implementation, operation, monitoring, and improvement. The checklist is written with certification readiness in mind, clearly linking each step to relevant ISO clauses and annexes. It is especially valuable for teams that already understand why AI governance matters and now need clarity on how to implement it in a structured, auditable way. The tone is pragmatic and implementation-driven, making it suitable as a project backbone for real-world AIMS rollouts rather than a purely conceptual framework.

🧩 What’s Covered

The checklist walks through the full ISO 42001 journey in a logical sequence. It starts with foundational governance prerequisites: obtaining senior management support and framing AIMS as a formal, cross-functional project (steps 1–2). It then moves into contextual analysis by defining the organization’s role in the AI ecosystem, identifying stakeholders, and scoping the AIMS realistically (steps 3–5).

A substantial portion is dedicated to governance design and risk management. This includes drafting the AI Policy, assigning roles and responsibilities, and establishing a repeatable AI risk assessment and treatment methodology (steps 6–7). The document clearly distinguishes between general AI risk assessment and the AI system impact assessment, emphasizing consequences for individuals and society (step 8). Outputs such as the Risk Register, Statement of Applicability, and Risk Treatment Plan are positioned as central governance artifacts (steps 9–10).

The checklist then addresses operationalization: defining supporting processes (resources, communication, document control), implementing Annex A controls with guidance from Annex B, and rolling out training and awareness programs (steps 11–13). Finally, it covers the “living system” aspects of ISO 42001: operating the AIMS in daily practice, monitoring and measurement, internal audits, management review, and corrective actions with continual improvement (steps 14–18). Each step is explicitly tied to ISO clauses, making traceability and audit preparation straightforward.

💡 Why it matters?

ISO 42001 often feels abstract to organizations facing real deployment pressures and regulatory deadlines. This checklist bridges that gap by turning governance requirements into an executable roadmap. It reduces the risk of superficial or “paper” compliance by emphasizing management ownership, documented decision-making, and continuous oversight. For organizations navigating the EU AI Act in parallel, the checklist also implicitly supports alignment by embedding risk assessment, impact analysis, and accountability mechanisms into day-to-day operations. In practice, it helps teams move from AI principles to auditable governance.

❓ What’s Missing

The checklist intentionally stays high-level and does not provide templates, examples of completed artifacts, or sector-specific adaptations. It also does not explicitly map ISO 42001 steps to EU AI Act obligations, which many EU-based organizations would expect. Readers still need complementary tooling or guidance to translate steps like risk assessment or impact assessment into concrete methodologies tailored to their AI use cases and maturity level.

👥 Best For

AI governance leads, compliance and risk professionals, ISO implementation project managers, and organizations preparing for ISO/IEC 42001 certification who need a clear, end-to-end implementation structure rather than theoretical guidance.

📄 Source Details

Article: ISO 42001 Checklist of Implementation Steps
Author: Dejan Kosutic
Publisher: Advisera Expert Solutions Ltd.
Year: 2025

📝 Thanks to

Dejan Kosutic and the Advisera team for translating a complex AI governance standard into a practical, implementation-ready checklist that organizations can actually use.

About the author
Jakub Szarmach

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