ISO/IEC 42001 Gap Assessment and Statement of Applicability
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On this page 7 sections
In brief
The ISO/IEC 42001 Gap Assessment and Statement of Applicability is a free XLSX assessment for ISO/IEC 42001. Every ISO/IEC 42001 clause and control the records map to, with the legal duties behind each, applicability, implementation status and evidence, in the form a Statement of Applicability takes. It is licensed CC BY 4.0 and is not legal advice.
- Format
- XLSX · Assessment
- Version
- v4, built 12 Nov 2026
- Duties cited
- 119 from 23 instruments
- Rows from the records
- 204
- Frameworks
- ISO/IEC 42001
- Written for
- Deployer / user organisation, Provider / developer, Public authority / government body
- Price and licence
- Free · CC BY 4.0
What's inside
- Gap sheet: each mapped clause, the duties and controls mapped to it, applicable and implemented dropdowns, evidence, gap, owner
- Statement of Applicability sheet, derived from the gap sheet by formula
- Mappings sheet: every recorded crosswalk with its confidence
Preview
The sheets and sections of version v4, as built. Columns marked ▾ have a dropdown; ƒ is a formula.
Sheet: Gap assessment
| ISO/IEC 42001 reference | Duties mapped | Controls mapped | Legal duties behind it | Recorded controls | Mapping confidence | Applicable ▾ | Justification (if not applicable) | Implementation ▾ | Evidence | Gap and action | Owner |
|---|---|---|---|---|---|---|---|---|---|---|---|
| Annex A.5.2, A.7.3 | 1 | 0 | Governmental entities must not use AI for biometric identification from public data without consent where it infringes rights (Texas Responsible AI Governance A | medium | |||||||
| Annex A.6.1.2, A.9.4 | 1 | 0 | Developers and deployers must not use AI with the intent to unlawfully discriminate against a protected class (Texas Responsible AI Governance Act (TRAIGA)) | medium | |||||||
| Annex A.6.2.4 | 0 | 2 | Accuracy, robustness, fairness and security testing; Adversarial and red-team testing for generative AI | high | |||||||
| Annex A.6.2.4; Clause 9.2 | 1 | 0 | Employers and employment agencies must obtain an independent bias audit before using an automated employment decision tool (NYC Local Law 144 (automated employm | medium | |||||||
| Annex A.6.2.5, A.9.2, A.9.3 | 0 | 1 | Human oversight design and override procedure | medium | |||||||
| Annex A.6.2.7, A.8.2, A.10.4 | 1 | 0 | Providers of GPAI models must maintain technical documentation and inform downstream providers (EU AI Act) | high |
The references are those the recorded duties and controls map to; the mappings are editorial, with a stated confidence, not the standard's text.
Sheet: Statement of Applicability
| Reference | Applicable ƒ | Implementation ƒ | Justification ƒ |
|---|---|---|---|
| Annex A.5.2, A.7.3 | = | = | = |
| Annex A.6.1.2, A.9.4 | = | = | = |
| Annex A.6.2.4 | = | = | = |
| Annex A.6.2.4; Clause 9.2 | = | = | = |
| Annex A.6.2.5, A.9.2, A.9.3 | = | = | = |
| Annex A.6.2.7, A.8.2, A.10.4 | = | = | = |
Derived from the gap sheet by formula: complete that sheet and this one follows.
Sheet: Controls
| Control | Kind | Purpose | Typical owner | Frequency | Duties it satisfies | Duties it supports | Evidence it produces | ISO/IEC 42001 | NIST AI RMF | Record |
|---|---|---|---|---|---|---|---|---|---|---|
| AI governance policy and accountability structure | Policy | Gives the organisation a single approved statement of how it will develop, buy and use AI, and names the people who are answerable for it, so that every other A | Executive sponsor for AI | annual | 9 | 8 | AI policy; Board or executive approval of the AI policy; AI governance forum minutes; AI responsibility map | Clause 5.1, 5.2, 5.3, 9.3; Annex A.2, A.3 | GOVERN 1.1, 1.2, 1.3, 2.1, 3.1 | https://aipolicytracker.org/controls/ai-governance-policy-and-accountability |
| AI impact and fundamental-rights impact assessment | Process | Examines how a planned AI use will affect the people, groups and communities it touches, with particular attention to discrimination and rights, and records the | AI system owner | per_system | 5 | 7 | AI impact assessment; Impact assessment approval; Impact assessment procedure and template | Clause 6.1.4, 8.4; Annex A.5 | MAP 5.1, 5.2; MEASURE 2.11 | https://aipolicytracker.org/controls/ai-impact-assessment |
| AI incident management and regulatory reporting | Process | Ensures that harm or near-harm caused by an AI system is detected, contained, investigated and, where a rule requires it, reported to the right authority and af | Incident coordinator | continuous | 9 | 7 | AI incident response playbook; AI incident record; Incident report to an authority | Clause 10.2; Annex A.8.3, A.8.4 | MANAGE 4.1, 4.3; GOVERN 4.3, 6.2 | https://aipolicytracker.org/controls/ai-incident-management-and-reporting |
| AI interaction and use disclosure notices | Process | Tells people, in plain language and at the right moment, that they are interacting with an AI system, that AI is being used in a decision about them or that the | Product owner | on_material_change | 19 | 4 | AI interaction or use notice; Notice catalogue; Notice wording approval | Annex A.8.2, A.8.5 | MEASURE 2.8; GOVERN 5.1 | https://aipolicytracker.org/controls/ai-interaction-and-use-disclosure |
| AI literacy and role-based training programme | Training | Gives everyone who builds, buys, operates or is overseen by AI systems the knowledge they need for their role, from general awareness to the specific skills of | Learning and development lead | annual | 1 | 3 | AI training completion records; Role-to-curriculum training matrix; AI training curriculum and materials | Clause 7.2, 7.3; Annex A.4.6 | GOVERN 2.2, 4.1 | https://aipolicytracker.org/controls/ai-literacy-and-role-based-training |
| AI risk assessment and lifecycle risk register | Process | Identifies, rates and treats the risks that a specific AI system poses to health, safety, rights and the organisation itself, and keeps that analysis alive from | AI system owner | per_system | 7 | 5 | AI system risk assessment; Per-system AI risk register; Residual-risk acceptance | Clause 6.1.2, 6.1.3, 8.2, 8.3 | MAP 3, MAP 4, MANAGE 1.2, 1.3, 2.1 | https://aipolicytracker.org/controls/ai-risk-assessment |
How to use it
- 1Request the files. Enter your name, company and work email in the form on this page. The XLSX download links arrive by email and work for 7 days.
- 2Read the README page. It states the version (v4), the dataset it was built from and the licence, so anyone reviewing your copy knows which records it reflects.
- 3Check the duties against your situation. The "Gap assessment", "Statement of Applicability" and "Controls" sheets list the recorded duties with their source references. Mark which apply to you and follow each link to the official text.
- 4Keep the evidence and watch for new versions. Link each completed row to the evidence that supports it. When the law on record changes, this template gets a new version and a changelog on this page.
Duties this template covers (119)
Each is cited in the file with its source reference and a link back to the record.
- Establish accountability processes and a risk-management process (guardrails 1 and 2)
- Test and monitor systems, enable human control, and be transparent with users (guardrails 4 to 6)
- Provide contestability, supply-chain transparency and records (guardrails 7 to 9)
- Give consumers a Pre-use Notice before using automated decision-making technology for a significant decision
- Let consumers opt out of automated decision-making technology for significant decisions, or offer a qualifying human appeal
- Answer consumers' requests to access information about how automated decision-making technology was used about them
- Conduct and document a risk assessment before processing that presents significant risk, including ADMT for significant decisions
- Submit risk assessment information to the California Privacy Protection Agency each year
- Large frontier developers must publish a frontier AI framework
- Report critical safety incidents to the Office of Emergency Services
- Frontier developers must publish a transparency report before deploying a new frontier model
- Large frontier developers must send periodic summaries of catastrophic-risk assessments to the state
Legal basis
Version history
| Version | Built | Dataset | What changed |
|---|---|---|---|
| v4 | ef1018b7a6a2 | Dataset 1e8ea28a8a93 → ef1018b7a6a2. | |
| v3 | 1e8ea28a8a93 | Dataset 3335c39da4b7 → 1e8ea28a8a93. | |
| v2 | 3335c39da4b7 | Dataset 914895c3103e → 3335c39da4b7. | |
| v1 | 914895c3103e | First version, built from dataset 914895c3103e. |
Only the latest version is served. A rebuild that changes the content adds a version; a rebuild that does not is skipped.
Frequently asked questions
What is in the ISO/IEC 42001 Gap Assessment and Statement of Applicability?
Gap sheet: each mapped clause, the duties and controls mapped to it, applicable and implemented dropdowns, evidence, gap, owner. Statement of Applicability sheet, derived from the gap sheet by formula. Mappings sheet: every recorded crosswalk with its confidence.
Which duties does it cite?
119 recorded duties from Australian Voluntary AI Safety Standard, California CPPA automated decision-making rules, California SB 53 and Colorado ADMT law (SB 26-189), including Guardrails 1 and 2, Guardrails 4, 5 and 6, Guardrails 7, 8 and 9, Cal. Code Regs. tit. 11, § 7220, Cal. Code Regs. tit. 11, § 7221 and Cal. Code Regs. tit. 11, § 7222. Each row links to the record, and the record to the official source.
Who is it for?
The duties it cites fall on deployer / user organisation, provider / developer and public authority / government body. Whoever owns AI governance for those roles usually completes it, with the system owner supplying the facts.
Is it free?
Yes. Request the XLSX with your work email on this page; the download links arrive by email, valid for 7 days. No account and no charge. Licensed CC BY 4.0. You may use, adapt and share this template, including commercially, with attribution to aipolicytracker.org.
How will I know when it changes?
Version v4 was built on 12 November 2026. The library is rebuilt daily; when a change to the records reaches this template it gets the next version, a changelog below and an entry in the templates feed.
Is there a self-assessment that goes with it?
Yes: the ISO/IEC 42001 Readiness Assessment (23 questions, about 6 minutes). It is free and runs on Certifyi, a related product. A score is a self-check, not an audit; this template is where the work it points to gets written down.
Does completing it make us compliant?
No. It is an informational resource, not legal advice; it helps produce the evidence a regulator, customer or auditor asks for. Whether a duty applies to you is a judgement the template cannot make.
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.