Carry the Obligations Across the Whole Life of the System
Do our controls cover the system before it exists and after it is switched off — or only while it runs?
Baseline: 1Enhanced: 23 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
Apply the framework across the entire life of each AI system — from before it is built to after it is retired — rather than only at the moment it launches. The common failure is to concentrate all governance at the go-live gate and let it lapse afterwards: the system is approved, and then it runs unwatched, drifts unmonitored, and is eventually abandoned rather than retired. Governance that stops at launch governs the least risky moment in a system’s life. Spread it across every phase, and make sure it reaches the phases everyone forgets — the design that precedes building, and the decommissioning that should follow abandonment.
What to actually do
Embed the obligations from design through to retirement, not only at launch. The relevant controls of every domain apply at every phase: requirements and design, building and adapting, deploying and integrating, operating and monitoring, and retiring. The framework already places controls across these phases; this dimension is the instruction to check that none of them lapses once a system is live — that monitoring, oversight, and risk management continue for as long as the system does.
Do not let launch be the last decision. Put approval gates between phases for systems above your risk threshold, and — the phase that is almost always skipped — treat retirement as a governed event with its own obligations: the secure disposition of data, the destruction or archival of the model, the purge of derived stores, and the revocation of every credential and connection, as set out in the Governance lifecycle. A system switched off without being retired is a standing risk that has merely gone quiet.
Controls
Baseline1 controls
Control 238
On retirement, delete or return the data the system held and revoke its credentials and connections.
BaselinePreventiveall rolesper system
What it is
The minimum every organisation does when a system is switched off, so that an abandoned agent’s keys do not remain a live door; the full decommissioning of Domain 1 adds model archival, purge of derived stores and knowledge transfer.
How to implement it · Steps
List what the system held: uploaded files, conversation history, data stored with the provider, connected folders
Delete it, or request deletion or return from the provider, and keep the confirmation
Revoke API keys, access tokens, service accounts and user licences
Disconnect integrations: email, file storage, business applications, webhooks, scheduled automations and any agent permissions
Record the date, who did it and what was removed or revoked
How to start
When a tool is switched off, the person who owned it completes a one-page checklist with these steps within the same week.
Evidence
The deletion or return confirmation and the revocation record for each retired system.
Mode: light / standard / full
light
The tool's owner works through the checklist and files the provider's deletion confirmation.
standard
IT completes it with the owner and checks the access-management system that nothing remains.
full
Retirement runs as a change ticket, with security verifying revocation and full decommissioning added.
Enhanced2 controls
Control 236
Apply the relevant controls of each domain across all lifecycle phases.
EnhancedPreventiveall rolesper system
What it is
Design, build, deploy, operate, and retire — with none lapsing once the system is live.
How to implement it · Minimum content
Phases: design, build or adapt, deploy or integrate, operate and monitor, retire
Per system: each applicable control mapped to the phase or phases in which it acts
Controls that must keep running after launch: monitoring, human oversight, risk refresh, access review, each with owner and frequency
Status per control: operating, lapsed, or not yet due
Check every six months that post-launch controls are still operating
Retirement controls listed in advance, before go-live
How to start
For each live system, list the controls applied at launch and check which are still operating today.
Evidence
The phase-control map with current status and the records produced by controls running in operation.
Mode: light / standard / full
light
Each system's owner keeps a short checklist per phase and ticks operating controls twice a year.
standard
Owners maintain the map; the governance lead reviews lapsed controls every six months.
full
Lifecycle status is tracked in the inventory system, with alerts on lapsed controls.
Control 237
Gate the transitions for higher-risk systems, and govern retirement as an event.
EnhancedPreventiveall rolesper system
What it is
Approval between phases; decommissioning with its full obligations, not a quiet switch-off.
How to implement it · Steps
Set the threshold: e.g. every system at Enhanced or Advanced passes through gates
Define gates design → build, build → deploy and operate → retire, each with a named approver and entry criteria
Treat a system with no owner or no use for a set period (e.g. three months) as due for retirement
Retirement plan: secure disposition of data, model destruction or archival, purge of derived stores, revocation of every credential and connection
Retirement sign-off only when the checklist is complete and evidenced
How to start
Write the retirement checklist and apply it first to any AI system that is no longer used but still switched on.
Evidence
The phase-transition approvals and completed retirement records per system.
Mode: light / standard / full
light
The owner-manager approves each transition by email and signs the retirement checklist.
standard
The AI governance lead approves transitions and retirement on the owner's evidence.
full
Gates are formal project steps approved by the AI committee; security verifies retirement.
Evidence
Evidence that controls persist through operation, not only at launch; phase-transition approvals; completed retirement records. Deletion or return records and revocation records per retired system.