AIGO — Cross-Framework Gap and Coverage Mapping
1. Document Purpose
This document defines the cross-framework gap-analysis and coverage model for the AIGO mapping layer connecting:- the European Union Artificial Intelligence Act;
- ISO/IEC 42001:2023; and
- NIST AI RMF 1.0.
- mapped;
- controlled;
- implemented;
- evidenced;
- monitored;
- assured;
- subject to a gap;
- subject to a framework-specific extension; or
- subject to a version or applicability issue.
2. Mapping Information
3. Core Principle
Cross-framework coverage is not the same as legal or normative compliance. The canonical chain is:4. Coverage Dimensions
The AIGO coverage model uses the following dimensions:5. Source Coverage
Source coverage asks:Are all declared framework sources and versions represented correctly in the repository?The repository should identify:
- framework;
- version;
- publication;
- effective date where relevant;
- mapping version;
- source status;
- review date.
6. Source Coverage Status
Possible values:7. Applicability Coverage
Applicability coverage asks:Has the organization determined which requirements apply?The model is:
8. Applicability Gap
An applicability gap exists when:- the framework applies but no assessment exists;
- system role is unresolved;
- classification is unresolved;
- AIMS scope is unclear;
- selected NIST scope is undocumented;
- applicability evidence is stale.
XFW-APPLICABILITY-GAP
9. Requirement Coverage
Requirement coverage asks:Has every applicable framework requirement or selected NIST outcome been mapped to AIGO?Possible statuses:
10. Requirement Coverage Gap
A requirement gap occurs when:XFW-REQUIREMENT-UNMAPPED
This is a higher-priority issue for binding legal requirements than for voluntary framework guidance.
11. Control Coverage
Control coverage asks:Does every applicable requirement have an adequate AIGO control or documented framework-specific extension?The model is:
12. Control Coverage Status
Possible values:13. Control Gap
A control gap exists when:XFW-CONTROL-GAP
14. Framework-Specific Control Gap
A common AIGO control may exist while a framework-specific extension is missing. Example:XFW-FRAMEWORK-EXTENSION-GAP
This is distinct from a complete absence of a base control.
15. Duplicate-Control Gap
Duplicate-control analysis identifies cases where:XFW-DUPLICATE-CONTROL
The result is a harmonization candidate, not automatically a defect.
16. False-Equivalence Gap
A false-equivalence gap occurs when:XFW-FALSE-EQUIVALENCE
This is a critical architectural validation rule.
17. Implementation Coverage
Implementation coverage asks:Has the mapped AIGO control actually been established?Possible states:
18. Implementation Gap
A control is mapped but not implemented:XFW-IMPLEMENTATION-GAP
19. Control Ownership Coverage
Every material control should have:- control owner;
- accountable owner;
- operational owner;
- evidence owner;
- assurance owner where applicable.
XFW-CONTROL-OWNER-GAP
20. Evidence Coverage
Evidence coverage asks:Is there sufficient evidence supporting the implementation of the relevant control and requirement?The model is:
21. Evidence Coverage Status
Possible values:22. Evidence Gap
Potential findings:23. Shared Evidence Coverage
AIGO should distinguish:24. Evidence Reuse Efficiency
AIGO may report:25. Monitoring Coverage
Monitoring coverage asks:Are implemented controls and AI-system risks being monitored where monitoring is required or appropriate?The model is:
26. Monitoring Gap
A monitoring gap exists where:- monitoring is required but absent;
- metrics exist but are not analyzed;
- thresholds are undefined where needed;
- alerts do not generate action;
- monitoring evidence is stale.
XFW-MONITORING-GAP
27. Assurance Coverage
Assurance coverage asks:Has the applicable requirement/control/evidence relationship been independently or objectively evaluated according to the defined AIGO assurance scope?Possible statuses:
28. Assurance Gap
Potential findings:29. Framework-Specific Assurance Coverage
Coverage must be calculated independently for:30. Remediation Coverage
Remediation coverage asks:Are identified gaps being corrected and independently verified?The model is:
31. Remediation Status
Possible values:32. Remediation Gap
A remediation gap exists when:- critical findings remain overdue;
- corrective actions lack owners;
- evidence is missing;
- verification has not occurred;
- repeated findings remain unresolved.
XFW-REMEDIATION-GAP
33. Version Coverage
Version coverage asks:Does each mapping relationship reference the correct source version?The model is:
34. Version Gap
Potential findings:35. Current EU AI Act Baseline
The current legal mapping must identify the AI Act’s governing text and applicable amendments. Regulation (EU) 2026/1744 amended Regulation (EU) 2024/1689 and entered into force on 27 July 2026. The cross-framework coverage engine must therefore not treat an older unamended AI Act snapshot as the current legal baseline.36. Current ISO Baseline
The ISO mapping baseline remains:ISO/IEC 42001:2023
ISO lists the standard as published, Edition 1, with publication date December 2023.
Future revisions or related standards must be separately versioned.
37. Current NIST Baseline
The NIST package uses:NIST AI RMF 1.0
Any future NIST revision must trigger controlled impact analysis before it changes coverage conclusions.
38. Traceability Coverage
Traceability coverage asks whether the complete relationship chain can be reconstructed:39. Traceability Gap
Potential findings:40. Reverse Traceability
Coverage should also work in reverse.From control
From evidence
From finding
41. Cross-Framework Harmonization Coverage
This dimension asks:How effectively has the organization reduced duplicate operational mechanisms while retaining framework-specific requirements?Possible statuses:
42. Harmonization Gap
A harmonization gap exists when:- identical operational processes are duplicated unnecessarily;
- common controls are defined separately without justification;
- evidence is duplicated;
- assurance is duplicated.
XFW-HARMONIZATION-GAP
43. Harmonization Boundary
Harmonization must stop where source-specific legal, normative, or technical requirements diverge. Therefore:44. Coverage Matrix
The cross-framework package should maintain a conceptual matrix:
This matrix is descriptive and should ultimately be generated from machine-readable registry relationships.
45. Coverage State Machine
The preferred lifecycle is:46. Requirement Coverage State
47. Control Coverage State
48. Evidence Coverage State
49. Assurance Coverage State
50. Gap Taxonomy
The master taxonomy should include:51. Gap Severity
AIGO may classify a gap as:- legal status;
- AI-system impact;
- safety;
- fundamental rights;
- risk;
- control criticality;
- evidence;
- recurrence.
52. Criticality Rule
A gap related to a binding legal requirement should generally receive higher priority than an otherwise comparable gap concerning an optional framework recommendation. However, actual severity remains dependent on the system and context.53. Priority Factors
Potential scoring dimensions:54. Gap Prioritization
AIGO should prioritize:55. Framework-Specific Gap
A framework-specific gap should be recorded when:56. Common-Control Gap
A common-control gap exists when several frameworks require related governance capabilities but no adequate AIGO control exists. Potential finding:XFW-COMMON-CONTROL-GAP
57. Evidence Gap
A common control exists and operates, but insufficient evidence exists. Example:58. Assurance Gap
Evidence exists but no assurance has been performed where assurance is required or planned. Example:59. Version Gap
A source framework changed but the AIGO mapping has not been updated. Example:STALE_MAPPING
60. Conflict Gap
A conflict exists where two requirements impose materially different obligations or interpretations. The correct response is:61. Coverage Report Structure
A generated cross-framework coverage report should contain:62. Framework Summary
The summary should identify:63. Do Not Aggregate Compliance Scores
The report must not claim:64. Common-Control Coverage
AIGO may additionally report:65. Gap Aging
Each open gap should record:- discovery date;
- due date;
- current status;
- owner;
- severity;
- days open.
OPEN_GAP_AGE
66. Overdue Gaps
A gap may become:OVERDUE
when its approved remediation date has passed.
Critical overdue gaps should be escalated through governance.
67. Repeat Gaps
If the same or materially similar gap recurs:REPEAT_GAP
should be recorded.
This can indicate:
- ineffective corrective action;
- control-design weakness;
- governance weakness;
- insufficient monitoring.
68. System-Level Coverage
Coverage should ultimately be computable per AI system:69. Portfolio-Level Coverage
Coverage should also roll up:70. Control-Level Coverage
For each AIGO control:71. Evidence-Level Coverage
For each evidence record:72. Assurance-Level Coverage
For each assurance activity:73. Coverage Automation
The AIGO validators should eventually calculate coverage automatically. Conceptual pipeline:74. Validation Rules
The cross-framework coverage validator should verify:75. Coverage Validator Outputs
Potential output categories:76. Warning vs Failure
A warning may represent:- optional evidence enhancement;
- low-priority gap;
- future framework change;
- harmonization opportunity.
- critical missing requirement;
- broken traceability;
- invalid reference;
- critical evidence failure;
- critical assurance failure.
77. Accepted Exceptions
Not every gap must block release if it is:- documented;
- risk-assessed;
- approved;
- time-bounded;
- monitored.
- rationale;
- owner;
- authority;
- expiry;
- compensating control.
78. V1 Release Gate
For AIGO v1, the cross-framework layer should require:79. V1 Critical-Failure Conditions
The cross-framework package should fail the v1 gate when:- a binding legal requirement is unmapped;
- a critical control has no owner;
- a critical requirement has no evidence;
- critical evidence references the wrong system/version;
- assurance claims exceed their criteria;
- source versions conflict without resolution;
- framework-specific obligations are incorrectly merged.
80. V1 Non-Blocking Conditions
Potential non-blocking items include:- low-priority evidence enhancement;
- future profile mappings;
- additional harmonization opportunities;
- optimized evidence reuse;
- low-risk duplicate-control candidates.
81. Cross-Framework Gap Registry
The machine-readable registry should eventually support:82. Gap Status
Possible values:83. Gap Relationship to AIGO Schemas
84. Gap Relationship to Tools
The following tools should eventually consume gap data:85. Cross-Framework Consistency
The consistency checker should identify:- same requirement mapped to contradictory controls;
- same control assigned different meanings;
- inconsistent framework versions;
- incompatible applicability;
- duplicate control identifiers;
- incompatible evidence relationships.
86. Repository Health Integration
Repository health should include:87. Management Dashboard
The consolidated dashboard should show:Framework Risk
- open critical gaps;
- high-risk gaps;
- overdue gaps.
Control Risk
- control gaps;
- ineffective controls;
- shared-control failures.
Evidence Risk
- evidence gaps;
- stale evidence;
- integrity problems.
Assurance Risk
- assurance gaps;
- overdue assurance;
- repeat findings.
Harmonization
- common controls;
- shared evidence;
- shared assurance;
- framework-specific extensions.
88. Gap Trend
The system should support tracking:89. Repeat-Finding Trend
Track:90. Evidence-Gap Trend
Track:91. Assurance-Gap Trend
Track:92. Common-Control Efficiency
AIGO may track:93. Shared-Evidence Efficiency
AIGO may track:94. Shared-Assurance Efficiency
AIGO may track:95. Framework-Specific Burden
The cross-framework layer should identify the additional operational burden created by framework-specific requirements. Examples:- extra evidence fields;
- extra testing;
- extra reporting;
- statutory deadlines;
- additional approval;
- external assessment.
96. Harmonization Decision Model
For each potential overlap:97. Gap Closure Model
A gap is closed only when:98. Framework-Specific Closure
A common control may close one framework gap while another remains open. Example:99. Control-Specific Closure
A control may be effective operationally while a framework-specific documentation extension remains open. Example:100. Gap Escalation
Critical or overdue gaps should escalate to:101. Legal Escalation
Legal or regulatory uncertainty should be routed to appropriate legal/compliance review rather than resolved by an automated equivalence algorithm.102. Source-Update Impact
A framework change should produce:103. Historical Gap State
Historical gaps should retain:- original requirement;
- version;
- finding;
- remediation;
- evidence;
- closure;
- assurance.
104. Gap Archive
Closed gaps should be archived, not deleted. The system should support:105. Cross-Framework Gap and Coverage Report
The final generated report should contain:106. Executive Summary Example
A future generated report may state:107. No Manual Coverage Claims
Coverage percentages should not be typed manually into mapping documents. They should be derived from:- the registry;
- validated requirements;
- controls;
- evidence;
- assurance;
- gap records.
108. Registry as Coverage Source
The cross-framework registry should become the machine-readable source for:109. Coverage Automation Architecture
The intended future pipeline is:110. Validation Output
The cross-framework validator should produce structured results such as:- identifier;
- severity;
- source framework;
- requirement;
- control;
- evidence;
- assurance;
- recommended action.
111. Repository-Level Release Gate
AIGO v1 should use the following sequence:112. V1 Release Status
Possible repository-level statuses:113. V1 Blocking Rule
A repository should be:BLOCKED
when any unaccepted critical issue exists in:
- source integrity;
- requirement mapping;
- control coverage;
- evidence;
- assurance;
- traceability;
- versioning.
114. V1 Warning Rule
A repository may be:READY_WITH_WARNINGS
when only:
- low-risk gaps;
- planned improvements;
- future framework updates;
- optional harmonization improvements;
115. V1 Ready Rule
A repository may be:READY
when:
116. Known-Limitations Register
The cross-framework package should maintain explicit limitations where:- source interpretation is unresolved;
- framework guidance is evolving;
- evidence is unavailable;
- legal applicability needs counsel;
- an external certification decision remains outstanding.
117. Governance of Gap Decisions
Gap acceptance should identify:- decision-maker;
- rationale;
- risk;
- compensating control;
- expiry date;
- next review.
118. Cross-Framework Gap Ownership
Each material gap should have:119. Gap Review Frequency
Open gaps should be reviewed according to:- severity;
- regulatory deadlines;
- risk;
- remediation complexity;
- framework requirement.
120. Final Coverage Architecture
The full model is:121. Final Principle
The AIGO cross-framework gap and coverage architecture follows one central principle:Measure coverage separately at every governance layer and separately for every framework, then use the common AIGO control architecture to identify where operational mechanisms can be shared and where framework-specific gaps remain.This prevents a common control, shared evidence record, or combined assurance activity from being mistaken for universal compliance.
122. Document Control
123. Document Status
Document: AIGO — Cross-Framework Gap and Coverage Mapping Version: 0.1 Status: Draft Working Name: AIGO Full Name: AI Governance Operating Framework Document Identifier:AIGO-MAP-XFW-005
Document Type: Cross-Framework Gap and Coverage Mapping
This document establishes the cross-framework gap taxonomy, coverage lifecycle, evidence and assurance coverage model, version controls, harmonization metrics, remediation workflow, and AIGO v1 release-gate criteria for the EU AI Act, ISO/IEC 42001, and NIST AI RMF mapping packages.
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