AIGO — Cross-Framework Requirements Mapping
1. Document Purpose
This document defines the cross-framework requirements mapping between:- the European Union Artificial Intelligence Act;
- ISO/IEC 42001:2023; and
- NIST AI RMF 1.0;
2. Mapping Information
3. Source Framework Baselines
The cross-framework requirements model currently uses:4. Normative Status
The cross-framework requirements model must preserve the different status of each source.
A relationship between requirements does not change these statuses.
5. Requirements Mapping Principle
The fundamental relationship is:6. Requirement Relationship Types
This document uses:DIRECT
The source requirements address substantially the same operational governance objective.PARTIAL
One source addresses only part of the operational objective.OVERLAPPING
The source requirements cover related governance subject matter but have different scope or criteria.COMPLEMENTARY
The requirements address different aspects of the same governance objective.INTEGRATED
Multiple source requirements can be operationalized through a common AIGO process.CONDITIONAL
The relationship applies only under specified applicability conditions.SUPPORTING
One requirement provides useful support for another but does not satisfy it.CONFLICTING
The requirements cannot safely be treated as a single requirement or control relationship without additional analysis.NO_DIRECT_EQUIVALENT
There is no defensible common requirement relationship.7. Requirement Identity Rule
Every requirement retains its original source identity. For example:8. Applicability Rule
Cross-framework mapping occurs only after framework-specific applicability is determined. The sequence is:9. Cross-Framework Requirement Matrix
The following matrix identifies major governance areas where the frameworks can be operationally connected.
This table is an architectural harmonization view, not a substitute for the individual framework mappings.
10. Governance Requirements
10.1 Common Objective
The common objective is:Establish accountable organizational governance for AI systems and AI-related risks.
EU AI Act
The EU AI Act establishes obligations that vary according to the role, system type, risk classification, and applicable provisions.ISO/IEC 42001
ISO/IEC 42001 establishes organizational management-system requirements covering context, leadership, planning, support, operation, performance evaluation, and improvement. ISO describes the standard as a management-system standard for organizations providing or using AI-based products or services.NIST AI RMF
GOVERN establishes organizational governance, policies, roles, and processes for AI risk management. NIST describes GOVERN as a cross-cutting function of the AI RMF Core.Cross-Framework Relationship
INTEGRATED
AIGO Control
AIGO-XFW-GOV-001
11. Context Requirements
11.1 Common Objective
Establish sufficient organizational and AI-system context to understand applicable requirements, risks, stakeholders, and impacts.EU AI Act
Context supports legal applicability, classification, role determination, and system-specific obligations.ISO/IEC 42001
Clause 4 establishes the organizational context and AIMS scope.NIST AI RMF
MAP establishes contextual understanding of AI systems, actors, impacts, and risks. NIST describes MAP as one of the four Core functions and states that AI risk management is performed throughout the AI lifecycle.Cross-Framework Relationship
DIRECT / INTEGRATED
AIGO Control
AIGO-XFW-CTX-001
12. AIMS and AI Governance Scope
12.1 Common Objective
Define the boundary within which AI governance requirements are applied.EU AI Act
The relevant legal scope depends on the Act’s applicability provisions and the organization’s role and AI activities.ISO/IEC 42001
The organization establishes the scope of its AIMS based on organizational context and relevant requirements.NIST AI RMF
NIST permits organizations to tailor AI RMF implementation to their context, use cases, and needs.Relationship
COMPLEMENTARY
AIGO Control
AIGO-XFW-APP-001
13. AI System Identification
13.1 Common Objective
Maintain a reliable inventory and identity for AI systems subject to governance.EU AI Act
System identity and classification support identification of applicable statutory obligations.ISO/IEC 42001
An AIMS requires organizational governance over relevant AI activities and systems.NIST AI RMF
MAP requires understanding the AI system and its context.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-CTX-001
AIGO Schema
AI System
14. AI Classification
14.1 Common Objective
Determine relevant categories or classifications before applying downstream controls.EU AI Act
The Act contains legal classifications including prohibited practices, high-risk AI, transparency-related obligations, and GPAI-related obligations.ISO/IEC 42001
Classification is context- and risk-dependent rather than a statutory EU AI Act-style risk taxonomy.NIST AI RMF
NIST uses contextual risk framing rather than a legally binding risk class taxonomy.Relationship
COMPLEMENTARY
Critical Rule
An organization’s internal AI risk rating must not be represented as the EU AI Act’s legal classification.AIGO Control
AIGO-XFW-CLS-001
15. AI Risk Management
15.1 Common Objective
Identify, analyze, evaluate, prioritize, treat, monitor, and reassess AI risks.EU AI Act
The AI Act establishes risk-management requirements for applicable AI systems, including high-risk systems.ISO/IEC 42001
The standard provides a management-system structure for managing AI-related risks and opportunities. ISO describes ISO/IEC 42001 as a management-system standard covering AI-related risks and opportunities.NIST AI RMF
MAP and MANAGE provide risk-context and risk-treatment functions. NIST describes AI RMF as a voluntary resource for managing AI risks and promoting trustworthy and responsible development and use.Relationship
DIRECT / INTEGRATED
AIGO Control
AIGO-XFW-RSK-001
16. Risk Treatment
16.1 Common Objective
Turn risk assessments into documented decisions and controls.EU AI Act
Applicable systems may have legally defined risk-management and risk-control obligations.ISO/IEC 42001
Risk and opportunity treatment forms part of AIMS planning and operation.NIST AI RMF
MANAGE uses risk analysis and measurement results to prioritize and respond to risk.Relationship
DIRECT / INTEGRATED
AIGO Control
AIGO-XFW-RSK-001
17. Residual Risk
17.1 Common Objective
Maintain an explicit decision regarding risk remaining after treatment.EU AI Act
Residual-risk concepts may arise within applicable system risk-management requirements.ISO/IEC 42001
Residual risk is relevant to risk-treatment and management-system decisions.NIST AI RMF
MANAGE addresses risk response and prioritization.Relationship
COMPLEMENTARY
AIGO Control
AIGO-XFW-RSK-002
18. Impact Assessment
18.1 Common Objective
Identify and assess potential impacts on individuals, groups, organizations, and society.EU AI Act
Applicable provisions address fundamental rights and other impacts depending on the AI system and actor.ISO/IEC 42001
AI impact and risk considerations can be incorporated into AIMS processes.NIST AI RMF
MAP includes understanding risks, impacts, harms, and context. NIST explicitly frames AI risk management around potential negative impacts as well as positive impacts and opportunities.Relationship
COMPLEMENTARY / INTEGRATED
AIGO Control
AIGO-XFW-IMP-001
19. Data Governance
19.1 Common Objective
Govern AI-related data according to its intended use, quality requirements, risk, privacy, fairness, security, and lifecycle.EU AI Act
Applicable high-risk AI requirements include data-governance requirements.ISO/IEC 42001
AIMS controls address AI data-related governance where applicable.NIST AI RMF
Data quality and measurement affect validity, reliability, fairness, privacy, and other trustworthiness considerations.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-DATA-001
20. AI Lifecycle Governance
20.1 Common Objective
Apply governance across the AI lifecycle.EU AI Act
Applicable obligations may arise before deployment, during operation, after deployment, and following relevant changes.ISO/IEC 42001
Operational planning and AI-system management operate within the AIMS.NIST AI RMF
The AI RMF Core is intended to operate across AI lifecycle dimensions. NIST states that AI risk management should be continuous and performed throughout the AI system lifecycle.Relationship
DIRECT / INTEGRATED
AIGO Control
AIGO-XFW-LIFE-001
21. Human Oversight
21.1 Common Objective
Ensure that human oversight is appropriately designed and operational where required.EU AI Act
Applicable high-risk AI requirements include human oversight.ISO/IEC 42001
Human-related governance and control mechanisms can be incorporated into the AIMS.NIST AI RMF
Human and organizational factors are integral to trustworthy AI risk management.Relationship
COMPLEMENTARY
AIGO Control
AIGO-XFW-HUM-001
Boundary
An organization must not treat a generic NIST or ISO human-oversight control as automatically satisfying an EU AI Act statutory requirement.22. Transparency
22.1 Common Objective
Provide appropriate information about AI systems, their operation, limitations, and relevant consequences.EU AI Act
The Act establishes specific transparency obligations for defined circumstances.ISO/IEC 42001
Transparency is incorporated into AI management-system governance.NIST AI RMF
Accountability and transparency are trustworthiness characteristics.Relationship
COMPLEMENTARY / INTEGRATED
AIGO Control
AIGO-XFW-TRANS-001
23. Performance Evaluation
23.1 Common Objective
Evaluate whether an AI system performs appropriately for its intended purpose and risk context.EU AI Act
Applicable high-risk requirements include accuracy, robustness, and cybersecurity-related requirements.ISO/IEC 42001
Performance evaluation forms part of the AIMS.NIST AI RMF
MEASURE evaluates AI risks and trustworthiness characteristics.Relationship
DIRECT / INTEGRATED
AIGO Control
AIGO-XFW-PERF-001
24. Safety
24.1 Common Objective
Identify, evaluate, control, and monitor safety risks.EU AI Act
Applicable AI systems may have statutory safety and risk-management requirements.ISO/IEC 42001
Safety can be addressed as an AI risk within the AIMS.NIST AI RMF
Safety is a trustworthiness characteristic.Relationship
COMPLEMENTARY
AIGO Control
AIGO-XFW-SAFE-001
25. Security and Resilience
25.1 Common Objective
Protect AI systems from security threats and support resilience.EU AI Act
Applicable requirements address cybersecurity and robustness.ISO/IEC 42001
Security-related AI controls can be integrated into the AIMS.NIST AI RMF
Secure and resilient is a trustworthiness characteristic.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-SEC-001
26. Privacy
26.1 Common Objective
Identify and manage privacy risks associated with AI systems.EU AI Act
Privacy and data-protection obligations interact with the AI Act but remain subject to applicable privacy law.ISO/IEC 42001
Privacy-related AI governance can be incorporated into the AIMS.NIST AI RMF
Privacy-enhanced is a trustworthiness characteristic.Relationship
COMPLEMENTARY
AIGO Control
AIGO-XFW-PRIV-001
Boundary
The EU AI Act mapping does not replace GDPR or other applicable privacy mappings.27. Fairness and Harmful Bias
27.1 Common Objective
Identify and mitigate unfairness, discrimination, and harmful bias.EU AI Act
Applicable provisions address discrimination, fundamental rights, and data/governance requirements.ISO/IEC 42001
Fairness-related risks may be governed through AI risk and impact processes.NIST AI RMF
Fairness with harmful bias managed is a core trustworthiness characteristic.Relationship
COMPLEMENTARY / INTEGRATED
AIGO Control
AIGO-XFW-FAIR-001
28. Explainability and Interpretability
28.1 Common Objective
Provide appropriate understanding of AI-system behavior.EU AI Act
Applicable transparency and information obligations depend on system type and role.ISO/IEC 42001
Explainability-related controls can be incorporated into the AIMS.NIST AI RMF
Explainability and interpretability are trustworthiness characteristics.Relationship
COMPLEMENTARY
AIGO Control
AIGO-XFW-EXP-001
29. Monitoring and Measurement
29.1 Common Objective
Measure and monitor AI-system and governance performance.EU AI Act
Applicable systems may have monitoring and post-market obligations.ISO/IEC 42001
Clause 9 provides the performance-evaluation layer.NIST AI RMF
MEASURE and MANAGE support ongoing risk monitoring.Relationship
DIRECT / INTEGRATED
AIGO Control
AIGO-XFW-MON-001
30. Incident Management
30.1 Common Objective
Identify, investigate, respond to, document, and learn from AI-related incidents.EU AI Act
Certain serious incidents create specific regulatory obligations.ISO/IEC 42001
Nonconformities, corrective actions, and improvement mechanisms support incident-related governance.NIST AI RMF
MANAGE includes incident response and learning.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-INC-001
Critical Boundary
The same incident record may support multiple frameworks, but statutory reporting criteria and deadlines remain framework-specific.31. Change Management
31.1 Common Objective
Assess and control material changes to AI systems and governance.EU AI Act
Certain changes can affect regulatory classification or obligations.ISO/IEC 42001
Management-system changes require controlled planning.NIST AI RMF
AI risks must be reassessed as context and systems evolve.Relationship
INTEGRATED / CONDITIONAL
AIGO Control
AIGO-XFW-CHG-001
32. Third-Party Governance
32.1 Common Objective
Control risks created by external providers, models, datasets, software, infrastructure, and services.EU AI Act
Role-specific provider/deployer/downstream obligations may apply.ISO/IEC 42001
Externally provided processes and services are part of management-system control.NIST AI RMF
AI supply-chain and third-party risk are relevant to AI risk management.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-TPG-001
33. Competence and AI Literacy
33.1 Common Objective
Ensure people performing AI governance activities have appropriate knowledge, skills, and awareness.EU AI Act
Article 4 establishes AI-literacy requirements for providers and deployers within the Act’s scope.ISO/IEC 42001
Competence and awareness are management-system requirements.NIST AI RMF
Governance requires appropriate organizational capability and multidisciplinary expertise.Relationship
INTEGRATED / CONDITIONAL
AIGO Control
AIGO-XFW-COMP-001
Boundary
EU AI Act AI-literacy compliance remains a separate statutory relationship from ISO competence and NIST governance capability.34. Documentation
34.1 Common Objective
Maintain controlled documentation supporting AI governance.EU AI Act
Applicable systems may require technical documentation and other regulated documentation.ISO/IEC 42001
Documented information is a core management-system requirement.NIST AI RMF
Documentation supports transparency, risk management, measurement, and accountability.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-DOC-001
35. Records and Logging
35.1 Common Objective
Maintain reliable records of governance actions and AI-system activity where required.EU AI Act
Applicable record-keeping and logging requirements may apply.ISO/IEC 42001
The AIMS requires controlled documented information and records.NIST AI RMF
Records support evidence and reproducibility of risk-management activities.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-REC-001
36. Assurance
36.1 Common Objective
Evaluate whether governance requirements and controls are appropriately implemented and effective.EU AI Act
Regulatory conformity mechanisms and statutory oversight are distinct from internal AIGO assurance.ISO/IEC 42001
Internal audit and management review provide management-system performance evaluation.NIST AI RMF
Organizations can evaluate implementation of selected AI RMF outcomes through their assurance processes.Relationship
COMPLEMENTARY / INTEGRATED
AIGO Control
AIGO-XFW-ASSR-001
37. Internal Audit and External Assessment
The cross-framework architecture must preserve:38. Management Review
38.1 Common Objective
Provide management with evidence-based information for governance decisions.EU AI Act
Management review may support organizational oversight but does not replace statutory obligations.ISO/IEC 42001
Management review is a direct management-system mechanism.NIST AI RMF
Governance decisions and risk-management outcomes can be incorporated into management review.Relationship
INTEGRATED
AIGO Control
AIGO-XFW-MREV-001
39. Corrective Action
39.1 Common Objective
Address failures, findings, incidents, and identified control weaknesses.EU AI Act
Corrective measures may be required by competent authorities or under applicable legal obligations.ISO/IEC 42001
Corrective action is part of continual improvement.NIST AI RMF
Risk treatment and iterative improvement support corrective action.Relationship
COMPLEMENTARY / INTEGRATED
AIGO Control
AIGO-XFW-IMPR-001
40. Continual Improvement
40.1 Common Objective
Use monitoring, incidents, assurance, and management decisions to improve AI governance.EU AI Act
Improvement activities can support ongoing compliance but do not replace mandatory legal action.ISO/IEC 42001
Continual improvement is a management-system requirement.NIST AI RMF
AI risk management is intended to operate iteratively and continuously. NIST states that risk management should be continuous, timely, and performed throughout AI-system lifecycle dimensions.Relationship
DIRECT / INTEGRATED
AIGO Control
AIGO-XFW-IMPR-001
41. Retirement
41.1 Common Objective
Terminate AI systems in a controlled manner while preserving required records and resolving residual obligations.EU AI Act
Applicable lifecycle, record, and post-deployment obligations may affect retirement.ISO/IEC 42001
AI-system lifecycle governance includes controlled lifecycle management.NIST AI RMF
Risk management continues through the AI lifecycle and should consider changing contexts and risks.Relationship
COMPLEMENTARY
AIGO Control
AIGO-XFW-RET-001
42. Framework-Specific Requirements
Not every requirement has a shared equivalent. The following categories should generally remain framework-specific.EU AI Act-specific
Examples include:- prohibited AI practices;
- statutory high-risk classification;
- GPAI-specific obligations;
- regulatory registration;
- CE/conformity mechanisms;
- statutory transparency obligations;
- regulatory reporting;
- enforcement;
- legally defined rights and remedies.
43. ISO/IEC 42001-Specific Requirements
Examples include:- AIMS scope;
- management-system planning;
- internal-audit programme;
- management review;
- management-system continual improvement;
- ISO-specific Annex A applicability and controls.
44. NIST AI RMF-Specific Elements
Examples include:- GOVERN;
- MAP;
- MEASURE;
- MANAGE;
- trustworthiness characteristics;
- NIST-specific profiles;
- voluntary tailoring;
- NIST implementation guidance.
45. Requirement Equivalence Rule
A cross-framework relationship must not be described as:46. Requirement-to-Control Relationship
The canonical relationship is:47. Requirement-to-Evidence Relationship
Evidence should be evaluated separately:48. Evidence Sufficiency
Potential outcomes:49. Requirement-to-Assurance Relationship
Assurance should remain criterion-specific:50. Common-Control Gap
A common control gap occurs when:XFW_CONTROL_GAP
rather than forcing an incorrect relationship.
51. Framework-Specific Gap
A framework-specific gap occurs when:XFW_FRAMEWORK_SPECIFIC_GAP
52. Cross-Framework Overlap
An overlap exists when several frameworks address materially related governance subject matter. Examples:- risk management;
- monitoring;
- governance;
- lifecycle;
- transparency;
- evidence.
53. Complementary Requirements
Complementary requirements should be retained where one framework adds something absent from another. Example:54. Conflicting Requirements
Where requirements differ materially:55. Version-Specific Requirement Mapping
Every mapping must identify:- framework;
- version;
- requirement;
- AIGO mapping version;
- control version.
56. Current NIST Version Rule
The NIST mapping currently uses AI RMF 1.0. NIST currently states that AI RMF 1.0 is being updated. Therefore, future NIST revisions must not silently alter this v0.1 mapping.57. Current ISO Version Rule
The ISO mapping currently uses:ISO/IEC 42001:2023
ISO lists this as Edition 1, published in December 2023.
Future revisions or related standards must be separately versioned.
58. Current EU AI Act Version Rule
The EU mapping must preserve the legal source and applicable amendments. Regulation (EU) 2026/1744 was adopted on 8 July 2026 and published on 24 July 2026 as an amendment to Regulation (EU) 2024/1689 and other EU legislation. The AIGO repository should therefore avoid using a generic, unversioned label such as:EU AI Act
as the sole machine-readable source identifier.
59. Cross-Framework Requirement Registry
The cross-framework registry should eventually maintain:60. Coverage Calculation
Cross-framework requirement coverage should be calculated as:61. No Universal Compliance Score
The repository must not produce a single value such as:97% compliant
by simply aggregating:
- EU AI Act coverage;
- ISO coverage;
- NIST coverage.
62. Framework-Specific Coverage
Instead:63. Cross-Framework Coverage View
A management dashboard may show:
Actual values should be generated from validated repository data.
64. Management Use
The cross-framework requirements mapping should enable management to identify:- common governance obligations;
- framework-specific obligations;
- resource concentration;
- duplicated activities;
- evidence reuse;
- assurance reuse;
- unresolved conflicts;
- regulatory exposure.
65. Implementation Boundary
This document identifies relationships. Detailed implementation instructions remain in:66. Control Boundary
Detailed control definitions remain in the AIGO Control Schema and control architecture. This document identifies which source requirements may be operationalized through those controls.67. Evidence Boundary
Detailed evidence definitions remain in:68. Assurance Boundary
Detailed assurance methodology remains in the framework-specific assurance mappings and the AIGO Assurance Schema. This document identifies requirements that may share assurance infrastructure.69. Validation Requirements
The cross-framework requirements mapping must pass:70. Potential Findings
Potential findings include:71. Critical Finding — False Equivalence
A particularly important v1 validation rule is:A source requirement must never be marked satisfied solely because another framework has a similar requirement mapped to the same AIGO control.Example:
72. Critical Finding — Missing Extension
Where a common control lacks a legally required framework-specific extension:73. Critical Finding — Evidence Reuse Error
If the same evidence is reused across frameworks but does not satisfy the criteria of one framework:XFW_EVIDENCE_GAP
must be generated for that relationship.
74. Critical Finding — Assurance Reuse Error
If an assurance conclusion is copied between frameworks without evaluating the separate criteria:XFW_ASSURANCE_GAP
or:
XFW_FALSE_EQUIVALENCE
should be raised.
75. Critical Finding — Version Conflict
If:XFW_VERSION_GAP
until the relationship is reconciled.
76. Final Cross-Framework Requirement Chain
The intended chain is:77. Final Requirement-Harmonization Principle
The AIGO cross-framework requirements layer follows one governing principle:Harmonize operational implementation, not the underlying requirements.AIGO should provide one coherent operating architecture where possible, while preserving the separate:
- legal requirements;
- standards requirements;
- voluntary framework outcomes;
- applicability rules;
- evidence criteria;
- assurance criteria;
- version histories.
78. Document Control
79. Document Status
Document: AIGO — Cross-Framework Requirements Mapping Version: 0.1 Status: Draft Working Name: AIGO Full Name: AI Governance Operating Framework Document Identifier:AIGO-MAP-XFW-002
Document Type: Cross-Framework Requirements Mapping
This document establishes the requirement-level harmonization architecture for the EU AI Act, ISO/IEC 42001, and NIST AI RMF mappings, connecting related source requirements to common AIGO governance objectives and controls while explicitly preserving framework-specific applicability, legal or normative status, evidence requirements, assurance criteria, and version history.
End of Document