Crosswalk pair

EU AI Act and ISO/IEC 42001, control by control

7 canonical controls in Keel’s library satisfy clauses of both EU AI Act and ISO/IEC 42001. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.

The overlap

What the two libraries have in common

Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.

7

Controls that satisfy both

Canonical controls that crosswalk to at least one clause of each.

8

In Keel’s library for EU AI Act

88% of them also map to ISO/IEC 42001.

16

In Keel’s library for ISO/IEC 42001

44% of them also map to EU AI Act.

14

Evidence artifacts expected

Across the shared controls, from Keel’s evidence guidance. Gathered once.

  • EU AI Act 2024 88%

    7 controls of 8 in Keel’s library for EU AI Act also map to ISO/IEC 42001.

  • ISO/IEC 42001 2023 44%

    7 controls of 16 in Keel’s library for ISO/IEC 42001 also map to EU AI Act.

The mapping

Controls that satisfy both

Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.

EU AI Act and ISO/IEC 42001 controls that satisfy both, with the clauses each maps to
Canonical control EU AI Act clauses ISO/IEC 42001 clauses
AI technical documentation Maintained technical documentation of an AI system’s design, development, and impact assessments, sufficient to demonstrate how it works and was built. HREQ-3 A.5.3, A.6.2.7
AI transparency & disclosure Clear information for users and interested parties, including disclosing when people are interacting with an AI system and how to use it appropriately. TRANS-1, HREQ-5 A.8.2, A.8.5
Human oversight of AI Appropriate human oversight of AI systems, so people can understand, monitor, and intervene in how an AI system operates - the named people who hold that oversight have the competence, the authority and the access to the system to exercise it, and the system is operated in the way the instructions supplied with it specify, inside the purpose it was assessed and approved for rather than whatever use it turns out to support. HREQ-6, HOBL-5 A.6.2.6, A.9.2
Data governance for AI Governance of the data used to develop and operate AI systems: sourcing, quality, provenance, and preparation of training and operational data. HREQ-2 A.4.3, A.7.2, A.7.3, A.7.4, A.7.5, A.7.6
AI system logging & record-keeping Automatic recording of events over an AI system’s lifetime, retained to support traceability, monitoring, and post-incident review. HREQ-4 A.6.2.8
AI verification, validation & robustness Testing that an AI system meets its requirements and performs with appropriate accuracy, robustness, and security before and during use. HREQ-7 A.6.2.4
AI monitoring & malfunction reporting Ongoing monitoring of AI systems in operation, with a process to detect, communicate, and report malfunctions and serious incidents. HOBL-5, HOBL-6, HOBL-7 A.6.2.6, A.8.4

Beyond the pair

Where else this work counts

A framework is lit when a shared control above also maps to it. Unlit means none of them do — an absence, not a judgment about that standard.

Also reached by these 7 controls

  • AI Governance Essentials
  • Amazon Appstore Child-Directed Apps
  • Apple App Store Kids Category
  • CIS Critical Security Controls
  • COPPA
  • ESG Essentials
  • GDPR
  • Google Play Families
  • HIPAA
  • ISO 9001
  • ISO/IEC 27001
  • NIST AI Risk Management Framework
  • NIST Cybersecurity Framework
  • NIST SP 800-171
  • NIST SP 800-53
  • PCI DSS
  • SOC 2
  • SOX (Sarbanes-Oxley) Section 404
  • US Employment Law - Federal Baseline

The thesis

Why this is one project, not two

On a crosswalk-native model, ISO/IEC 42001 mostly lights up controls you already built for EU AI Act. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.

Next step

Add ISO/IEC 42001 to the work you already did

Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.