ISO 42001 - Control A.9 / B.9 – Use of AI Systems

Created in February 24, 2026

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ISO 42001 - Control A.9 / B.9 – Use of AI Systems by [Kimova AI](https://kimova.ai)

Control A.9 / B.9 – Use of AI Systems

In todays article by Kimova AI, we explore Annex A Control A.9 / B.9 – Use of AI Systems, a foundational control that governs how AI systems are used within an organization and by external users. From an ISMS auditor’s perspective, this control is essential for ensuring that AI is used responsibly, securely, ethically, and in alignment with organizational objectives and risk tolerance.

While previous controls focus on development, data, and transparency, Control A.9/B.9 shifts the emphasis toward the operational use phase of AI systems—where real-world risks, impacts, and compliance obligations become most visible.

Objective of Control A.9 / B.9

The primary objective of this control is to ensure that the use of AI systems is:

  • Authorized
  • Controlled
  • Monitored
  • Aligned with organizational policies and governance frameworks

It requires organizations to establish clear rules and safeguards governing how AI systems are accessed, deployed, and used across different business functions.

Scope of “Use of AI Systems”

This control applies to both:

  • Internal use of AI tools by employees
  • External use of AI systems by customers or end-users

This includes AI-driven decision systems, generative AI tools, automation platforms, and AI-enabled analytics solutions.

As auditors, we often observe that risks emerge not from AI development itself, but from uncontrolled or unintended usage of AI systems in operational environments.

Key Requirements Under Annex A Control A.9 / B.9

To conform with ISO/IEC 42001 expectations, organizations should ensure:

  • Defined Acceptable Use Policies

Clear policies must govern how AI systems can and cannot be used within the organization.

  • User Awareness and Training

Users should understand AI limitations, risks, ethical considerations, and operational constraints.

  • Access Control and Authorization

Only authorized personnel should be permitted to use specific AI systems, especially high-impact or sensitive applications.

  • Monitoring and Oversight

Usage should be logged, monitored, and reviewed to detect misuse, anomalies, or unintended outcomes.

  • Risk-Based Usage Controls

Higher-risk AI systems should have stricter usage controls, human oversight, and escalation mechanisms.

Governance and Risk Implications

Improper use of AI systems can lead to:

  • Biased or unfair decisions
  • Data privacy violations
  • Security incidents
  • Regulatory breaches
  • Reputational damage

This is why Kimova AI emphasizes integrating AI usage governance into the broader AI Management System (AIMS) and ISMS frameworks, ensuring traceability and accountability across the lifecycle.

Practical Implementation Strategies

Organizations can strengthen compliance with this control by:

  • Establishing an AI usage governance framework

  • Maintaining a register of approved AI systems

  • Implementing user access reviews and periodic audits

  • Deploying usage monitoring and logging mechanisms

  • Creating role-based AI usage guidelines

  • Conducting regular awareness and training sessions

Additionally, aligning AI system usage policies with internal security, ethics, and compliance policies enhances audit readiness and operational maturity.

Audit Perspective: What Auditors Look For

During ISO/IEC 42001 audits, evidence commonly reviewed includes:

  • AI acceptable use policies
  • User training records
  • Access control logs
  • AI system usage monitoring reports
  • Governance committee oversight records
  • Risk assessments related to AI usage

Organizations that lack structured control over AI usage often face nonconformities related to governance, accountability, and risk management.

Conclusion

Annex A Control A.9/B.9 highlights a critical reality: Responsible AI is not only about how systems are built—but also about how they are used.

By establishing structured controls over AI system usage, organizations can minimize risks, enhance transparency, and demonstrate strong governance aligned with ISO/IEC 42001 requirements. With the right frameworks in place, organizations can leverage AI confidently while maintaining compliance and stakeholder trust.

In tomorrow’s article by Kimova.AI, we’ll explore Annex A Control A.9.2 – Processes for Responsible Use of AI Systems, where we’ll explore how organizations can establish structured processes to ensure AI systems are used ethically, securely, and in accordance with defined governance, compliance, and risk management requirements.

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