ISO 42001 - Organizational Roles, Responsibilities, and Authorities (Clause 5.3)

Created in June 09, 2025

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ISO 42001: Organizational Roles, Responsibilities, and Authorities (Clause 5.3) with TurboAudit by [Kimova AI](https://kimova.ai)

A governance framework, no matter how well-designed, can only succeed when people know what they are responsible for and are empowered to act. Clause 5.3 of ISO/IEC 42001 emphasizes the importance of defining and communicating clear roles, responsibilities, and authorities within the Artificial Intelligence Management System (AIMS).

This clause builds on the previous requirements by ensuring the AIMS has structure and accountability, not just intention.

What Clause 5.3 Requires

According to ISO 42001, top management must:

  • Ensure roles and responsibilities are assigned for relevant functions across the AIMS.
  • Communicate these roles and responsibilities within the organization.
  • Assign authority to ensure that AIMS requirements are effectively implemented, maintained, and improved.

These assignments should not be ad hoc—they must be purposeful, documented, and aligned with the scope and complexity of AI activities in the organization.

Why Role Clarity Matters in AI Governance

AI governance requires collaboration across technical, legal, compliance, operational, and ethical domains. Without clear responsibilities:

  • Tasks fall through the cracks, especially those that aren’t tied to day-to-day operations, such as model risk assessments or AI ethics reviews.
  • Decisions lack accountability, making it harder to trace back errors or ethical breaches.
  • Efforts get duplicated or delayed, reducing the efficiency of the AIMS.

Clear assignment of roles ensures that everyone knows their part, from data labeling to final deployment decisions, and that someone is accountable for each stage in the AI lifecycle.

Common Roles in an AI Governance Framework

While the standard does not prescribe specific titles, effective AIMS implementations often include:

  • AI Governance Officer: Oversees AIMS implementation, ensures compliance, leads policy development
  • Data Protection Officer / Privacy Lead: Handles compliance with data laws and privacy impact assessments
  • Model Owner / System Owner: Accountable for a specific AI system’s design, performance, and compliance
  • AI Ethics Committee / Board: Advises on ethical concerns, fairness, and risk trade-offs
  • Developers and Engineers: Implement technical safeguards, documentation, testing
  • Legal and Compliance Teams: Ensure regulatory adherence, risk reporting, and contractual obligations

Each organization will shape these roles based on its size, industry, and maturity level.

Implementation Recommendations

  1. Map your AI lifecycle: Identify every step from data collection to model retirement. Then assign responsibilities accordingly.
  2. Document roles formally: Include them in job descriptions, governance policies, or a RACI (Responsible, Accountable, Consulted, Informed) matrix.
  3. Ensure authority matches responsibility: Those responsible for compliance must have the authority to make or influence key decisions.
  4. Review regularly: As your AI use cases evolve, revisit who holds which roles and whether they remain effective.

Supporting A Culture of Accountability

Beyond formal assignments, organizations should foster a culture of shared responsibility around AI. That means encouraging team members to speak up about ethical or technical concerns, empowering cross-functional collaboration, and avoiding the mindset that AI governance is “someone else’s job.”

An AI Management System is only as strong as the people who operate it—and the clarity they have in doing so.

In tomorrow’s article, we will move to Clause 6.1: Actions to Address Risks and Opportunities, where we explore how organizations can proactively identify and respond to risks posed by or to AI systems, and how this forms the backbone of responsible AI governance.

Stay tuned, and subscribe if you haven’t already—this journey through ISO 42001 is just beginning.

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