AIGO — Cross-Framework Control Mapping
1. Document Purpose
This document establishes the cross-framework control mapping between:- the EU AI Act;
- ISO/IEC 42001:2023; and
- NIST AI RMF 1.0;
- Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744, for the EU AI Act mapping.
- ISO/IEC 42001:2023 for the AI management-system mapping. ISO lists it as the published first edition from December 2023.
- NIST AI RMF 1.0 / NIST AI 100-1 for the NIST mapping. NIST describes AI RMF as voluntary and states that version 1.0 is currently being updated.
2. Mapping Information
3. Core Principle
The cross-framework architecture is:4. Source Framework Characteristics
NIST explicitly describes AI RMF as intended for voluntary use.
ISO describes ISO/IEC 42001 as specifying requirements for an AI Management System.
The EU AI Act is an EU regulation, and Regulation (EU) 2026/1744 amends Regulation (EU) 2024/1689.
5. Mapping Relationship Types
This document uses:6. Common-Control Model
The preferred AIGO architecture is:7. Framework-Specific Extension Model
Where a common control is not sufficient:8. Common Control Domains
The initial cross-framework common-control domains are:9. GOV-001 — AI Governance and Accountability
AIGO Control:AIGO-XFW-GOV-001
Objective: Establish accountable governance for AI systems, AI risk, controls, decisions, and oversight.
Framework relationships
EU AI Act: Governance and organizational obligations; framework-specific regulatory governance requirements. ISO/IEC 42001: Leadership, policy, organizational roles, responsibilities, authorities, and AIMS governance. NIST AI RMF: GOVERN function, including organizational governance, accountability, policies, and processes. Relationship:DIRECT / INTEGRATED
Evidence
- governance charter;
- role assignments;
- accountability matrix;
- decision authority;
- management-review records.
Assurance
Verify that assigned owners have actual authority and that governance decisions are evidenced.10. GOV-002 — AI Policy and Governance Policy
AIGO Control:AIGO-XFW-GOV-002
Objective: Establish and maintain governing policies for AI use and AI risk management.
Framework relationships
EU AI Act: Supports organizational governance and applicable policy obligations. ISO/IEC 42001: AI policy and management-system governance. NIST AI RMF: GOVERN policies and organizational practices. Relationship:DIRECT / SUPPORTING
Evidence
- approved AI policy;
- version history;
- approval;
- communication;
- review.
11. CTX-001 — AI System Context
AIGO Control:AIGO-XFW-CTX-001
Objective: Maintain a current description of the AI system, intended purpose, deployment environment, dependencies, users, and affected parties.
Framework relationships
EU AI Act: Supports applicability, classification, risk, transparency, rights, and lifecycle decisions. ISO/IEC 42001: Context of the organization and AI-system management. NIST AI RMF: MAP function. NIST’s AI RMF Core uses MAP to establish context and understand AI risks across the lifecycle. Relationship:DIRECT / INTEGRATED
12. CTX-002 — Stakeholder and Affected-Person Context
AIGO Control:AIGO-XFW-CTX-002
Objective: Identify relevant stakeholders, users, affected persons, and communities.
Framework relationships
EU AI Act: Supports fundamental-rights and transparency-oriented governance. ISO/IEC 42001: Interested parties and organizational context. NIST AI RMF: MAP and multidisciplinary stakeholder considerations. Relationship:DIRECT / COMPLEMENTARY
13. APP-001 — Regulatory and Framework Applicability
AIGO Control:AIGO-XFW-APP-001
Objective: Determine which requirements from each framework apply to a specific organization, AI system, activity, or lifecycle stage.
Framework relationships
EU AI Act: Legal applicability and classification. ISO/IEC 42001: AIMS scope and applicable management-system requirements. NIST AI RMF: Organizational selection and tailoring of applicable AI RMF outcomes. NIST’s framework is designed to be flexible and tailored by organizations rather than used as a mandatory checklist. Relationship:DIRECT / INTEGRATED
Critical rule
An applicable legal requirement must not be marked optional merely because the corresponding NIST outcome is voluntary.14. CLS-001 — AI Classification and Risk Categorization
AIGO Control:AIGO-XFW-CLS-001
Objective: Determine the relevant regulatory, governance, and risk classification of an AI system.
Framework relationships
EU AI Act: AI-system classification and applicable risk category. ISO/IEC 42001: Contextual AI-system management and risk determination. NIST AI RMF: MAP-based risk context. Relationship:DIRECT / COMPLEMENTARY
The legal classification under the EU AI Act must remain separate from an organization’s internal risk rating.
15. RSK-001 — AI Risk Management
AIGO Control:AIGO-XFW-RSK-001
Objective: Identify, analyze, evaluate, prioritize, treat, monitor, and reassess AI risks.
Framework relationships
EU AI Act: Risk-management requirements for applicable AI systems. ISO/IEC 42001: AI-related risks and opportunities within the AIMS. NIST AI RMF: MAP and MANAGE functions. Relationship:DIRECT / INTEGRATED
Evidence
- risk assessment;
- risk register;
- treatment;
- residual-risk decision;
- monitoring.
16. RSK-002 — Residual Risk Management
AIGO Control:AIGO-XFW-RSK-002
Objective: Maintain a documented decision concerning risk remaining after controls.
Framework relationships
EU AI Act: Supports residual-risk and risk-management analysis where applicable. ISO/IEC 42001: Risk treatment and management-system planning. NIST AI RMF: MANAGE risk treatment and prioritization. Relationship:DIRECT / SUPPORTING
17. IMP-001 — AI Impact Assessment
AIGO Control:AIGO-XFW-IMP-001
Objective: Identify and evaluate potential impacts on people, groups, organizations, and society.
Framework relationships
EU AI Act: Fundamental-rights and applicable impact-assessment obligations. ISO/IEC 42001: Impact and risk-related management activities. NIST AI RMF: MAP context and impacts. Relationship:COMPLEMENTARY / INTEGRATED
Impact assessment is not necessarily identical across frameworks, so the evidence requirement must remain framework-specific where necessary.
18. DATA-001 — AI Data Governance
AIGO Control:AIGO-XFW-DATA-001
Objective: Govern data used by AI systems according to applicable quality, provenance, privacy, fairness, security, and lifecycle requirements.
Framework relationships
EU AI Act: Data-governance and data-quality obligations for applicable AI systems. ISO/IEC 42001: AI data governance and related controls. NIST AI RMF: Measurement, risk, validity, fairness, privacy, and trustworthiness considerations. Relationship:DIRECT / INTEGRATED
19. LIFE-001 — AI Lifecycle Governance
AIGO Control:AIGO-XFW-LIFE-001
Objective: Apply governance controls throughout the AI lifecycle.
Framework relationships
EU AI Act: Lifecycle-oriented regulatory obligations. ISO/IEC 42001: AIMS operational planning and AI-system lifecycle management. NIST AI RMF: AI RMF functions apply across the AI lifecycle. NIST explicitly states that AI RMF risk management is intended to continue throughout the AI-system lifecycle. Relationship:DIRECT / INTEGRATED
20. CTRL-001 — Common AI Control Management
AIGO Control:AIGO-XFW-CTRL-001
Objective: Establish, maintain, assign, monitor, and review AI governance controls.
Framework relationships
All three frameworks use control or risk-management mechanisms that can be operationalized through this common AIGO control layer. Relationship:INTEGRATED
21. DOC-001 — AI Documentation Governance
AIGO Control:AIGO-XFW-DOC-001
Objective: Maintain controlled AI governance documentation and technical/governance documentation appropriate to the applicable framework.
Framework relationships
EU AI Act: Technical documentation and required records where applicable. ISO/IEC 42001: Documented information. NIST AI RMF: Documentation and evidence supporting governance, measurement, and risk-management activities. Relationship:DIRECT / INTEGRATED
22. REC-001 — AI Record Keeping
AIGO Control:AIGO-XFW-REC-001
Objective: Preserve material AI governance records with appropriate attribution, integrity, retention, and retrieval.
Framework relationships
EU AI Act: Applicable record-keeping and logging obligations. ISO/IEC 42001: Documented information and retained records. NIST AI RMF: Evidence supporting governance and risk-management activities. Relationship:DIRECT / INTEGRATED
23. HUM-001 — Human Oversight
AIGO Control:AIGO-XFW-HUM-001
Objective: Establish and maintain appropriate human oversight for AI systems where required by context, risk, or law.
Framework relationships
EU AI Act: Human-oversight requirements for applicable systems. ISO/IEC 42001: Human-related AI governance and operational controls. NIST AI RMF: Human and organizational considerations within trustworthy AI and risk management. Relationship:DIRECT / COMPLEMENTARY
The EU AI Act relationship is source-specific and must not be inferred solely from NIST or ISO mappings.
24. TRANS-001 — AI Transparency
AIGO Control:AIGO-XFW-TRANS-001
Objective: Govern relevant transparency information made available to users, affected persons, operators, and other stakeholders.
Framework relationships
EU AI Act: Statutory transparency obligations. ISO/IEC 42001: Transparency-related management-system controls. NIST AI RMF: Accountable and transparent trustworthiness characteristics. NIST’s AI RMF Core identifies accountability and transparency as trustworthiness considerations. Relationship:COMPLEMENTARY / INTEGRATED
25. PERF-001 — AI Performance Evaluation
AIGO Control:AIGO-XFW-PERF-001
Objective: Evaluate whether AI-system performance is appropriate for the intended purpose and risk context.
Framework relationships
EU AI Act: Accuracy, robustness, reliability, and other applicable performance requirements. ISO/IEC 42001: Performance evaluation and AI-system governance. NIST AI RMF: Valid and reliable trustworthiness characteristic and MEASURE function. Relationship:DIRECT / INTEGRATED
26. SAFE-001 — AI Safety Governance
AIGO Control:AIGO-XFW-SAFE-001
Objective: Identify, evaluate, mitigate, and monitor safety risks.
Framework relationships
EU AI Act: Applicable safety requirements. ISO/IEC 42001: AI risk and operational controls. NIST AI RMF: Safe trustworthiness characteristic. Relationship:DIRECT / COMPLEMENTARY
27. SEC-001 — AI Security and Resilience
AIGO Control:AIGO-XFW-SEC-001
Objective: Govern cybersecurity, resilience, integrity, and recovery risks associated with AI systems.
Framework relationships
EU AI Act: Cybersecurity and robustness requirements where applicable. ISO/IEC 42001: AI security-related management-system controls. NIST AI RMF: Secure and resilient trustworthiness characteristic and MEASURE/MANAGE activities. Relationship:DIRECT / INTEGRATED
28. PRIV-001 — AI Privacy Risk Governance
AIGO Control:AIGO-XFW-PRIV-001
Objective: Identify and manage privacy risks arising from AI systems and associated data.
Framework relationships
EU AI Act: Privacy-related AI governance interfaces. ISO/IEC 42001: AI privacy-related management controls. NIST AI RMF: Privacy-enhanced trustworthiness characteristic. Relationship:SUPPORTING / COMPLEMENTARY
Privacy laws such as the GDPR remain separate legal sources.
29. FAIR-001 — Fairness and Harmful Bias
AIGO Control:AIGO-XFW-FAIR-001
Objective: Identify, evaluate, mitigate, and monitor harmful bias and fairness risks.
Framework relationships
EU AI Act: Applicable bias, discrimination, and rights-related obligations. ISO/IEC 42001: AI risk and impact governance. NIST AI RMF: Fairness with harmful bias managed. Relationship:DIRECT / COMPLEMENTARY
30. EXP-001 — Explainability and Interpretability
AIGO Control:AIGO-XFW-EXP-001
Objective: Govern explanation and interpretability capabilities appropriate to the AI system and its context.
Framework relationships
EU AI Act: Applicable transparency and human-information requirements. ISO/IEC 42001: Explainability and transparency-related AIMS controls. NIST AI RMF: Explainable and interpretable trustworthiness characteristic. Relationship:COMPLEMENTARY
31. MON-001 — AI Monitoring and Measurement
AIGO Control:AIGO-XFW-MON-001
Objective: Continuously or periodically monitor AI-system risks, performance, controls, incidents, and relevant trustworthiness indicators.
Framework relationships
EU AI Act: Applicable monitoring and post-market requirements. ISO/IEC 42001: Monitoring, measurement, analysis, and evaluation. NIST AI RMF: MEASURE and MANAGE, with continuous lifecycle application. NIST describes risk management as continuous and intended to operate across the AI lifecycle. Relationship:DIRECT / INTEGRATED
32. INC-001 — AI Incident Management
AIGO Control:AIGO-XFW-INC-001
Objective: Detect, classify, investigate, contain, report where required, remediate, and learn from AI-related incidents.
Framework relationships
EU AI Act: Applicable serious-incident and regulatory reporting requirements. ISO/IEC 42001: Nonconformity, incident, and improvement processes. NIST AI RMF: MANAGE incident response and learning. Relationship:DIRECT / INTEGRATED
The regulatory reporting obligation itself remains framework-specific.
33. CHG-001 — AI Change Management
AIGO Control:AIGO-XFW-CHG-001
Objective: Ensure material AI-system and governance changes are evaluated for risk, control, documentation, evidence, and assurance impact.
Framework relationships
EU AI Act: Applicable change and significant-change consequences. ISO/IEC 42001: Management-system change planning. NIST AI RMF: Reassessment as risk context evolves. Relationship:DIRECT / INTEGRATED
34. TPG-001 — AI Third-Party Governance
AIGO Control:AIGO-XFW-TPG-001
Objective: Govern externally provided AI models, data, software, services, and infrastructure.
Framework relationships
EU AI Act: Applicable provider, deployer, downstream, and supply-chain obligations. ISO/IEC 42001: Externally provided processes and services. NIST AI RMF: Supply-chain and third-party risk. Relationship:DIRECT / INTEGRATED
35. COMP-001 — AI Competence and Literacy
AIGO Control:AIGO-XFW-COMP-001
Objective: Ensure personnel have competence and awareness appropriate to their AI governance responsibilities.
Framework relationships
EU AI Act: AI literacy requirements where applicable. ISO/IEC 42001: Competence and awareness. NIST AI RMF: Governance, multidisciplinary capability, and responsible AI risk management. Relationship:INTEGRATED / CONDITIONAL
The legal AI-literacy requirement remains separately mapped in the EU AI Act package.
36. EVD-001 — Common Evidence Management
AIGO Control:AIGO-XFW-EVD-001
Objective: Maintain a common evidence management process while preserving framework-specific evidence requirements.
Framework relationships
All three frameworks can use a common AIGO Evidence infrastructure. Relationship:INTEGRATED
Evidence metadata
- evidence ID;
- system ID;
- control ID;
- framework relationship;
- source;
- version;
- period;
- owner;
- status;
- integrity;
- review.
37. EVD-002 — Evidence Traceability
AIGO Control:AIGO-XFW-EVD-002
Objective: Maintain bidirectional traceability between external requirements, AIGO controls, evidence, and assurance.
DIRECT / CRITICAL
38. ASSR-001 — Common Assurance Framework
AIGO Control:AIGO-XFW-ASSR-001
Objective: Provide a shared assurance process while preserving framework-specific criteria and conclusions.
Framework relationships
- NIST AI RMF assurance;
- ISO/IEC 42001 management-system assurance;
- EU AI Act readiness / regulatory assurance.
INTEGRATED
Critical boundary
39. ASSR-002 — Relationship-Specific Assurance
AIGO Control:AIGO-XFW-ASSR-002
Objective: Ensure assurance conclusions are calculated against the correct framework criterion.
A single control may therefore have:
40. MREV-001 — Cross-Framework Management Review
AIGO Control:AIGO-XFW-MREV-001
Objective: Provide management with a consolidated view of framework coverage, gaps, findings, and regulatory exposure.
Inputs
- control coverage;
- evidence coverage;
- assurance coverage;
- open findings;
- regulatory changes;
- framework changes;
- material incidents.
Outputs
- priorities;
- resource decisions;
- corrective actions;
- control changes;
- mapping changes.
41. IMPR-001 — Common Continual Improvement
AIGO Control:AIGO-XFW-IMPR-001
Objective: Feed cross-framework findings into the common AIGO improvement process.
42. RET-001 — Common AI Retirement Governance
AIGO Control:AIGO-XFW-RET-001
Objective: Ensure retirement decisions consider all applicable framework obligations and preserve required historical evidence.
Framework relationships
- EU AI Act lifecycle and retention requirements where applicable;
- ISO/IEC 42001 lifecycle governance;
- NIST AI RMF MANAGE and lifecycle risk management.
COMPLEMENTARY / INTEGRATED
43. Common-Control Matrix
This matrix is an architectural harmonization view. The individual framework mappings remain authoritative for exact requirements.
44. Framework-Specific Extensions
Common controls frequently require extensions.Example: Risk
Example: Transparency
Example: Assurance
45. Control Effectiveness by Framework
A control’s effectiveness must be relationship-specific. Example:46. Evidence Reuse Model
A shared evidence record may support multiple framework relationships:47. Evidence Sufficiency
The cross-framework registry should distinguish:48. Assurance Reuse Model
A single assurance activity may cover multiple frameworks where:- all relevant criteria are defined;
- evidence is sufficient;
- reviewer competence is appropriate;
- scope is explicit.
49. Shared Finding Model
Where a common AIGO control fails:50. Cross-Framework Gap Model
The cross-framework engine should distinguish:51. Conflict Management
ACONFLICTING relationship requires:
- explicit identification;
- source citations;
- applicability analysis;
- resolution decision;
- responsible reviewer;
- versioned outcome.
52. Duplicate-Control Detection
If two framework-specific mappings point to operationally identical AIGO controls, the validator should flag potential duplication. Potential result:XFW-CONTROL-DUPLICATE-CANDIDATE
Human review should determine whether controls can be consolidated.
53. Control Rationalization
Where rationalization is appropriate:54. Cross-Framework Coverage
The cross-framework coverage model should support:55. Reverse Traceability
The system should answer:From requirement
From control
From evidence
From assurance
56. Machine-Readable Relationship Example
00-AIGO-Cross-Framework-Mapping-Registry-v0.1.json
57. Cross-Framework Control Governance
Each common control should have:- owner;
- description;
- objective;
- applicability;
- frequency;
- evidence;
- monitoring;
- assurance;
- framework relationships;
- version.
58. Registry Integration
This document must remain aligned with:00-AIGO-Cross-Framework-Mapping-Registry-v0.1.json
The registry is the machine-readable relationship authority.
59. Existing Mapping Integration
This mapping consumes the existing packages:60. Existing AIGO Control Integration
The common-control layer must ultimately resolve to the controls represented in:61. Evidence Integration
Evidence relationships should resolve to:62. Assurance Integration
Assurance relationships should resolve to:63. Risk Integration
Risk relationships should resolve to:64. Assessment Integration
Applicability and framework-impact assessments should use:65. Change Integration
Cross-framework impacts of system or framework changes should use:66. Improvement Integration
Cross-framework remediation should use:67. Management Review Integration
Cross-framework management reporting should use:68. Retirement Integration
Historical cross-framework relationships should remain linked to retired systems through:69. Validation Requirements
The mapping should pass:70. Cross-Framework Findings
Potential findings:71. Critical Cross-Framework Findings
Potential critical findings include:- a binding requirement has no applicable control;
- a common control is incorrectly presented as legal equivalence;
- evidence is reused across frameworks despite insufficient scope;
- assurance conclusions are incorrectly transferred between frameworks;
- source versions conflict;
- a framework-specific statutory obligation is hidden inside a generic control.
72. V1 Control-Harmonization Objective
The v1 objective is not to maximize the number of mapped relationships. It is to establish a defensible common-control model in which:73. Current Framework Baselines
EU AI Act
The current legal source includes Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744. EUR-Lex identifies Regulation (EU) 2026/1744 as the Digital Omnibus on AI amendment adopted on 8 July 2026 and published on 24 July 2026.ISO/IEC 42001
ISO/IEC 42001:2023 remains the published first edition.NIST AI RMF
NIST AI RMF 1.0 remains the current mapping baseline while NIST is updating the framework.74. Version-Control Rule
Every cross-framework relationship must identify the source version it was mapped against. The repository must never infer:75. Historical Mapping
Historical mappings must remain reconstructable:76. Future Framework Expansion
Future mappings can be integrated through the same architecture:77. Final Control Architecture
The complete relationship is:78. Final Principle
The AIGO cross-framework control architecture follows one central rule:Map multiple frameworks to a common operational control system, but never erase the distinctions between their requirements, applicability, evidence, assurance, and legal or normative status.The goal is one AIGO operating model with multiple explicit framework relationships—not one separate governance system for every framework.
79. Document Control
80. Document Status
Document: AIGO — Cross-Framework Control Mapping Version: 0.1 Status: Draft Working Name: AIGO Full Name: AI Governance Operating Framework Document Identifier:AIGO-MAP-XFW-001
Document Type: Cross-Framework Control Mapping
This document establishes the shared AIGO control layer connecting the EU AI Act, ISO/IEC 42001, and NIST AI RMF mappings to reusable operational controls, evidence, monitoring, assurance, findings, corrective action, and continual improvement while preserving each source framework’s distinct legal, normative, voluntary, and version-specific characteristics.
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