Lesson 10 of 10 · 15 min read

Implementing ISO/IEC 27090 in your organization

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Implementing ISO/IEC 27090 starts with an inventory of every AI system and AI feature, including those inside vendor software. The existing ISO/IEC 27001 risk assessment is then extended with AI assets and the twelve threats, gaps are mapped to ISO/IEC 27002 controls, and priority controls are applied: prompt injection defences, data provenance, logging and endpoint protection. A six-month roadmap with named owners and a quarterly review cycle completes the adoption.

In this lesson you will learn to

  • 01

    Describe the inventory-first approach and the risk tier rule

  • 02

    Extend an ISO/IEC 27001 risk assessment with AI assets and threats

  • 03

    Map ISO/IEC 27090 themes to ISO/IEC 27002:2022 controls

  • 04

    Use the four templates and the six-month roadmap, and state the limits of the standard

Start with the inventory

Nothing in the standard can be applied to a system the organization has not listed. The first step is a register of every model, assistant, vendor AI feature and data pipeline, with its purpose, AI type, source, data used and classification, exposure, owners and risk tier. The register must include AI features inside purchased software, because most AI in an organization arrives that way, and shadow AI found through expense records and network data.

A simple risk tier rule keeps the register useful. High: personal or confidential data, external exposure, or decisions about people or money. Medium: internal use with confidential data. Low: public data and no decisions. The tier decides which controls apply and which systems are assessed first.

Extend the existing risk assessment

The standard and its reviewers agree on the method: extend the ISO/IEC 27001 risk assessment rather than build a parallel AI process. Add training data, models, pipelines, prompts and retrieval stores as assets. Add the twelve threats as threat sources. Score likelihood and impact per system, record existing controls and gaps, and decide treatments with owners and dates.

A workable scoring rule: likelihood times impact on one-to-five scales; fifteen or more is treated before go-live, eight to fourteen within the quarter, below eight is accepted with a recorded decision. Reassess on retraining, vendor version change, new data source, new tool connected, incident, or at least annually.

Mapping to ISO/IEC 27002:2022

Most of the work is extending the scope of controls that already exist. The table shows where each ISO/IEC 27090 theme lands in ISO/IEC 27002:2022 and what is genuinely new.

ISO/IEC 27090 themeISO/IEC 27002:2022 controlWhat is new for AI
AI asset inventory5.9 Inventory of information and other associated assetsModels, data sets, prompts and pipelines as asset types
Threat identification5.7 Threat intelligence; ISO/IEC 27001 clause 6 risk assessmentTwelve AI threats; asset and objective tagging
Supplied models and data5.19 to 5.21 Supplier relationships and ICT supply chainAI bill of materials; backdoors survive fine-tuning
Logging and monitoring8.15 Logging; 8.16 Monitoring activitiesPrompts, outputs, model and template versions, tool calls
Secure development8.25 Secure development life cycle; 8.31 Separation of environments; 8.4 Access to source codeNotebooks, checkpoints and retrieval stores as protected assets
Architecture and access8.27 Secure system architecture; 8.5 Secure authentication; 8.20 Networks securityRate limiting, output limiting, per-client baselines on inference endpoints
Testing8.29 Security testing in development and acceptance; 8.8 Technical vulnerabilitiesAdversarial testing, red teaming, combined control evaluation, revalidation after retraining
Incident management5.24 to 5.28 Incident managementPlaybooks for poisoning, leakage and injection-driven actions

Four templates

Four documents carry the implementation. An AI system inventory register, one row per system, with the fields above. A threat and risk assessment, one per system, with one row per catalogue threat scored for that system. A control mapping and gap analysis that records each theme, the ISO/IEC 27002 control, status, evidence, action and owner, and doubles as the audit evidence package. And an AI security policy with a responsibility matrix: the CIO accountable for the inventory and life cycle, the security lead for assessment, controls, monitoring and incident response, product owners for individual systems, data owners for provenance, and legal and privacy consulted throughout.

A six-month roadmap

Four phases, then a quarterly cycle. The priority controls in phase three, prompt injection defences, data provenance, logging with versions, and rate and output limits, give the most risk reduction for the effort.

PhaseFocusOutputs
Days 0 to 30Inventory and ownersRegister complete; owner per system; policy outline approved; systems tiered
Days 30 to 60Assess and find gapsRisk assessment for high-tier systems; control mapping; supplier questionnaires sent; residual risk reported
Days 60 to 120Priority controlsPrompt injection defences; data provenance checks; logging with versions; rate and output limits
Days 120 to 180Test, monitor, evidenceRed team of high-tier systems; drift and anomaly monitoring live; incident playbooks and tabletop exercise; evidence package
QuarterlySustainReassess on change; review the inventory; report AI risk to the risk committee

What the CIO and the security lead each own

The CIO owns the inventory as the starting point, an owner for every life-cycle stage, the treatment of models, data sets and MLOps tools as supply chain, the budget for monitoring and revalidation as an operating cost, and the link to governance through ISO/IEC 42001 and ISO/IEC 38507 and the risk committee.

The security lead owns the extension of the existing risk assessment, the ISO/IEC 27002 baseline with zero trust, logging and monitoring emphasised, the use of the catalogue in threat modelling and red teaming, the detection capability, the rule that model output and external content are untrusted in every integration, and incident response playbooks for AI-specific incidents, including the decision in advance on when a model is pulled from service.

Limits to keep in mind

The standard focuses on deliberate attacks; supplement it with ISO/IEC 23894 and the organization’s incident history for accidental failures and insider misuse. It is not certifiable and gives no legal presumption; map to the EU AI Act or ETSI where a certifiable route is needed. It took four years to write and agents, tool use and new injection techniques will outrun it; pair it with living sources such as the OWASP Top 10 for LLM applications, MITRE ATLAS and vendor advisories. Reviewers also note loose use of terms such as threat, failure and compromise. None of this reduces its value as the reference; it shows where to supplement.

Buy the standard. This course summarises it; the implementation team needs the text to verify clause wording, Annex A and Annex B before the templates are finalised.

Key terms

AI system inventory
A register of every AI system and AI feature an organization builds or uses, with owner, data, exposure and risk tier.
Gap analysis
A comparison of the controls a standard expects with the controls in place, recording status, evidence and actions.
Responsibility matrix
A table assigning who is responsible, accountable, consulted and informed for each activity.
Evidence package
The documented controls, test results and decisions that let an auditor or regulator verify a claim.
Zero trust
An architecture that verifies every access and grants least privilege, applied here to data provenance and agent permissions.

In one paragraph

Implementation begins with an inventory and a risk tier rule, extends the existing ISO/IEC 27001 risk assessment with AI assets and the twelve threats, and maps gaps to ISO/IEC 27002:2022 controls, most of which already exist and only need wider scope. Four templates, an inventory register, a per-system risk assessment, a control gap analysis and a policy with responsibility matrix, carry the work through a six-month roadmap. The CIO owns inventory, life cycle and budget; the security lead owns assessment, controls, detection and incident response. The standard’s limits show where to supplement it.

Lesson 10 quiz

Five questions. Score 4 or more to mark the lesson complete. Each answer shows an explanation, so a wrong answer teaches as much as a right one.

Question 1

Q1What is the first step in implementing ISO/IEC 27090?

Question 2

Q2Under the risk tier rule in this lesson, which system is high tier?

Question 3

Q3Which ISO/IEC 27002:2022 controls does the logging theme map to?

Question 4

Q4What is the recommended relationship between ISO/IEC 27090 and the existing ISO/IEC 27001 risk assessment?

Question 5

Q5Which of these is a stated limit of ISO/IEC 27090?

Questions people ask

Where should an organization start with ISO/IEC 27090?
With an inventory of every AI system and AI feature, including those inside vendor software, each with an owner and a risk tier. Everything else in the standard is applied per system from that register.
Do we need a separate AI risk process?
No. The recommended approach is to extend the existing ISO/IEC 27001 risk assessment with AI assets and the twelve threats, so AI risk is managed through the same governance as everything else.
Which controls give the most risk reduction first?
Prompt injection defences, data provenance checks, logging with model and template versions, and rate and output limits on inference endpoints. They address the most likely attacks for the least effort.

Shahzad Asghar

Senior IT Strategy and Portfolio Officer at UNRWA, with more than twenty years building and securing data and AI systems across UN agencies. He holds the CISM and CISSP security certifications and writes on AI governance, AI security and assurance, and digital transformation. Connect on LinkedIn.

This course is an independent educational resource by Shahzad Asghar. It is not affiliated with, endorsed by or published by ISO or IEC. ISO/IEC 27090:2026 is copyrighted and is sold through the ISO Store and national standards bodies; this course summarises it and does not reproduce its text. Last reviewed: .