Area 1.5

Lifecycle and Decisions

How is an AI approved?

Baseline: 2Enhanced: 4Advanced: 1 7 controls

Who it applies to

Enter for every AI system. Go as deep as your system letter, and implement in your mode.

Why it exists

Make every AI system pass through defined gates on its way into production — and make leaving production as deliberate as arriving. AI that appears in production by accident, because a pilot quietly became permanent or a feature toggle was never revisited, is AI that no one approved, no one owns, and no one will retire. Impose a lifecycle: every system is requested, evaluated, approved, deployed, monitored, and — the step almost everyone forgets — retired, in that order, with a decision at each transition. Six phases, then: request, evaluation, approval, deployment, monitoring, retirement.

What to actually do

Controls

Baseline 2 controls

Control 31

Define the request-to-retirement lifecycle and route every AI system through it.

BaselinePreventiveall rolesper system

What it is

No system reaches production outside the six phases.

How to implement it · Minimum structure
  • Six phases: request, evaluation, approval, deployment, monitoring, retirement
  • For each phase: entry condition, who decides, minimum record kept
  • Request form: purpose, AI Owner, data used, users, expected benefit
  • Rule: nothing reaches production without a recorded approval; pilots carry an end date
  • Retirement as a planned phase, not an afterthought
  • Each system's current phase shown in the register
How to start

Write a one-page description of the six phases and the decision at each, and place every existing system in its current phase in the register.

Evidence

The lifecycle description and register entries showing each system's phase and decisions.

Mode: light / standard / full
light
The owner-manager approves each transition and records it in the inventory spreadsheet.
standard
AI Owners move systems through the phases with a shared form, and the AI lead checks no system skips approval.
full
The lifecycle runs in a workflow tool with mandatory gates linked to the register.

Control 32

Approve every system before deployment, at a weight proportionate to its risk.

BaselinePreventiveall rolesper system

What it is

Light for low stakes, multi-party for high stakes — but always an explicit decision by an accountable person.

How to implement it · Minimum rules
  • Approval levels tied to the risk class, written down in advance
  • Low risk (internal, no personal data, no decisions about people): the AI Owner approves with a short record
  • Medium risk: AI Owner plus Technology Owner, with a security and privacy check
  • High risk (rights, money, health or safety): multi-party sign-off and named acceptance of residual risk
  • Every approval records approver, date, risk class and conditions
  • No deployment without a recorded approval
How to start

Define two or three approval levels tied to the risk class and use them for the next system requested.

Evidence

The approval records, each showing approver, date and risk class.

Mode: light / standard / full
light
The owner-manager approves every system, with a one-line record for low risk and a written note of the risks accepted for anything higher.
standard
Approval rights are assigned per level and the AI lead keeps the approval log.
full
Approval levels are enforced in the workflow tool, with high-risk approvals routed to the committee.

Enhanced 4 controls

Control 33

Open each initiative with a charter that includes an explicit out-of-scope boundary and a named sign-off.

EnhancedPreventiveall rolesper system

What it is

Scope changes re-open the charter; they do not bypass it.

How to implement it · Minimum structure
  • Purpose and the business objective it serves
  • In scope: what the initiative will do
  • Out of scope: what it explicitly will not do (e.g. will not make or recommend decisions about individuals)
  • Stakeholders
  • Success measures and how they will be checked
  • Named sign-off
  • Rule: any change of scope re-opens the charter and needs a new sign-off
How to start

Adopt a one-page charter template and require a signed charter before work starts on the next initiative.

Evidence

Signed charters with their out-of-scope lines and any re-opened versions.

Mode: light / standard / full
light
The owner-manager signs a one-page charter written by whoever proposes the initiative.
standard
The AI Owner writes and signs the charter, and the AI lead checks it before evaluation begins.
full
Charters are held in the portfolio system, with scope changes routed back through formal re-approval.

Control 34

Operate a sanctioned experimentation environment.

EnhancedPreventiveall rolesper system

What it is

Isolated from production, without sensitive data or production credentials, with defined graduation criteria.

How to implement it · Minimum rules
  • Separated from production systems and networks
  • Only non-sensitive or synthetic data
  • No production credentials or connectors to internal systems
  • Each experiment registered: owner, purpose, end date
  • Graduation criteria: charter, risk class and approval through the lifecycle before any production use
  • Experiments past their end date closed and their data deleted
How to start

Set up one isolated workspace with synthetic or public data and publish the rules for using it.

Evidence

The sandbox rules, the experiment register and graduation records.

Mode: light / standard / full
light
Use a separate trial account with the provider, holding no company data, and keep the experiment list in a spreadsheet.
standard
IT provides an isolated environment and the AI lead tracks experiments and graduations.
full
A managed experimentation platform enforces isolation and data rules technically, with graduation through the approval workflow.

Control 35

Require multi-party sign-off for high-risk systems.

EnhancedPreventiveall rolesper system

What it is

Risk, security, privacy, compliance, and the business each sign, and the residual risk is recorded and owned.

How to implement it · Minimum content
  • Signatories: risk, security, privacy, compliance and the business (AI Owner)
  • Each signatory's findings and conditions
  • Residual risk after mitigations, described in plain terms
  • Named person who accepts the residual risk, with authority under the risk appetite
  • Version of the system approved and date
  • Any refusal blocks go-live until resolved or escalated
How to start

Create a sign-off sheet with the five signature lines and a residual-risk section, and attach it to the next high-risk approval.

Evidence

Completed sign-off sheets with named residual-risk acceptance.

Mode: light / standard / full
light
Commission external advice for the specialist views, and the owner-manager signs the acceptance of residual risk.
standard
Existing managers sign for each function, coordinated by the AI lead.
full
Each function signs through the approval workflow, and the committee authorises go-live on the completed record.

Control 36

Evaluate and document impact before deployment.

EnhancedPreventiveall rolesper system

What it is

The evaluation covers the people affected, not only the technology.

How to implement it · Minimum structure
  • System description, purpose and context of use
  • People affected: who, how many, and any vulnerable groups
  • Possible harms: errors, unfair treatment, privacy intrusion, loss of opportunity, safety
  • Mitigations and the human oversight in place
  • Remaining impact and the conclusion: proceed, proceed with conditions, or stop
  • Review on any change of purpose, data or affected population
How to start

Complete a short impact template for the next system before approval, with the AI Owner and someone who knows the people affected.

Evidence

The completed impact evaluations attached to the approval records.

Mode: light / standard / full
light
The owner-manager and the AI Owner fill a two-page template together.
standard
The AI Owner leads the evaluation with privacy and the relevant business area, and the AI lead reviews it.
full
A structured evaluation by a specialist team, with consultation of affected groups for high-risk systems and committee review.

Advanced 1 controls

Control 37

Execute planned decommissioning for every retirement.

AdvancedPreventiveall rolesper system

What it is

Data disposition, model archival or destruction, purge of derived stores, credential and connection revocation, and knowledge transfer — evidenced, not assumed.

How to implement it · Steps
  1. Data: return, archive or delete what the system held, according to its retention rules
  2. Model: archive or destroy it, and record which
  3. Derived stores: purge indexes, caches, summaries and logs built from its data
  4. Access: revoke every credential, key, token and connector the system or its agents held, and verify none still works
  5. Knowledge: document what the system did, its decisions and dependencies, and hand over to whoever takes on the work
  6. Close: mark the asset retired in the register, with the AI Owner's sign-off and evidence for each step
How to start

Turn these steps into a checklist and require evidence for every line before the next retired asset is closed.

Evidence

Decommissioning records, including proof of credential and connector revocation.

Mode: light / standard / full
light
A named person works through the checklist using the provider's account-closure and deletion settings; the owner-manager signs it.
standard
The Technology Owner executes the checklist and the AI Owner signs off the evidence.
full
Decommissioning runs as a managed change with automated revocation checks and independent verification before closure.

Evidence

Charters with their out-of-scope lines; sandbox usage and graduation records; approval and sign-off records with named residual-risk acceptance; impact evaluations; decommissioning records including revocation evidence.