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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;
and the common AIGO control architecture. The purpose is to identify where multiple external frameworks can be operationalized through a single AIGO control while preserving the individual framework’s source requirements, applicability, evidence expectations, and assurance conclusions. The cross-framework layer is therefore an integration layer, not a replacement for the individual framework mappings. The current framework baselines are:
  • 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.
This document does not establish legal compliance, ISO certification, NIST endorsement, or statutory conformity.

2. Mapping Information


3. Core Principle

The cross-framework architecture is:
The existence of a shared control does not mean the underlying requirements are legally or normatively identical.

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:
These describe relationships between requirements and controls. They are not legal equivalence statements.

6. Common-Control Model

The preferred AIGO architecture is:
rather than creating separate operational controls for every external source. A common control should only be shared when its design, operating procedure, evidence, and monitoring can genuinely address the relevant requirements.

7. Framework-Specific Extension Model

Where a common control is not sufficient:
For example:
This allows the common operational control to remain reusable while preserving source-specific requirements.

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.
and:
Relationship: 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.
Relationship: 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:
This relationship-specific model is required to avoid false cross-framework conclusions.

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.
Relationship: 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:
This is preferable to one universal status because the source requirements may differ.

46. Evidence Reuse Model

A shared evidence record may support multiple framework relationships:
The registry should preserve the relationship and sufficiency for each framework.

47. Evidence Sufficiency

The cross-framework registry should distinguish:
An evidence record cannot be treated as universally sufficient merely because it is shared.

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.
The final conclusions must remain framework-specific.

49. Shared Finding Model

Where a common AIGO control fails:
This supports one root-cause and one improvement process without losing framework-specific traceability.

50. Cross-Framework Gap Model

The cross-framework engine should distinguish:
These should not be combined into one generic “compliance gap.”

51. Conflict Management

A CONFLICTING relationship requires:
  • explicit identification;
  • source citations;
  • applicability analysis;
  • resolution decision;
  • responsible reviewer;
  • versioned outcome.
The cross-framework layer must not resolve legal conflicts by silently selecting a preferred framework.

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:
The same control can therefore be evaluated from multiple perspectives.

55. Reverse Traceability

The system should answer:

From requirement

From control

From evidence

From assurance


56. Machine-Readable Relationship Example

The actual registry is defined separately in: 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.
The underlying operational definition belongs to the AIGO Control architecture.

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:
The cross-framework layer should not duplicate their narrative content.

60. Existing AIGO Control Integration

The common-control layer must ultimately resolve to the controls represented in:
and the corresponding control documentation. The cross-framework mapping should not create a second uncontrolled control database.

61. Evidence Integration

Evidence relationships should resolve to:
and the AIGO Evidence Record template.

62. Assurance Integration

Assurance relationships should resolve to:
and the AIGO Assurance template.

63. Risk Integration

Risk relationships should resolve to:
and the AIGO Risk Assessment template.

64. Assessment Integration

Applicability and framework-impact assessments should use:
rather than creating framework-specific assessment record structures unnecessarily.

65. Change Integration

Cross-framework impacts of system or framework changes should use:
and the AIGO Change Management template.

66. Improvement Integration

Cross-framework remediation should use:
and the AIGO Continuous Improvement template.

67. Management Review Integration

Cross-framework management reporting should use:
and the AIGO Management Review template.

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:
are achieved without false equivalence.

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:
from:
without explicit version metadata.

75. Historical Mapping

Historical mappings must remain reconstructable:

76. Future Framework Expansion

Future mappings can be integrated through the same architecture:
The common AIGO control architecture therefore becomes the scalable integration point.

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. End of Document