Area 9.4

Treat Each Risk in Proportion, and Prove the Treatment Works

Have we actually reduced the risks we said we would — and checked?

Enhanced: 1Advanced: 1 2 controls

Who it applies to

Enter for every AI system whose letter is E or A (this area has no Baseline controls). Go as deep as your system letter, and implement in your mode.

Why it exists

For each risk that matters, decide the treatment in proportion to the risk, and then prove the treatment actually works — because a mitigation assumed to work and never tested is a risk you have relabelled as safe. Treatment does not mean eliminate; it means reduce to within the appetite the organisation set, by the proportionate means, and confirm the reduction is real. For the highest-stakes risks, confirmation includes deliberately trying to break the mitigation.

What to actually do

Controls

Enhanced 1 controls

Control 227

Treat each priority risk proportionately, with residual risk explicitly accepted.

EnhancedPreventiveall rolesper system

What it is

Accepted by an authority to accept it; connected to the go-live gate.

How to implement it · Minimum content
  • Risk identifier and its assessed rating
  • Treatment chosen in proportion to the rating: reduce, avoid, transfer or accept
  • Measures: the controls applied, owner and due date
  • Residual rating after treatment, compared with the risk appetite
  • Acceptance: name and role of the person with authority to accept, date and any conditions
  • Reference to the go-live decision for the system
How to start

Define who may accept which level of residual risk (e.g. system owner for low, management for high), then record the treatment of the highest-rated risks.

Evidence

The treatment decisions and the signed residual-risk acceptances referenced in go-live records.

Mode: light / standard / full
light
The owner-manager accepts all residual risk by signing the risk spreadsheet.
standard
Owners accept low and medium; management accepts high at the go-live gate.
full
An authority matrix routes acceptance to owners, committee or executive by rating.

Advanced 1 controls

Control 228

Validate treatments, and adversarially test them for high-stakes risks.

AdvancedDetectiveall rolesper system

What it is

Mitigations proven, not assumed; the highest-stakes ones attacked.

How to implement it · Steps
  1. Define a pass criterion per treatment (e.g. the input filter stops at least 95% of a test set of injection prompts)
  2. Validate before go-live and after each change, keeping test cases and results
  3. For high-stakes risks, commission an adversarial exercise to try to defeat the mitigation
  4. Record findings; revise any mitigation that failed and re-test it
  5. Repeat the adversarial test at least annually per high-stakes system and on major change
How to start

Take the three highest-rated risks and write for each a test that would show whether its mitigation actually works.

Evidence

Validation and adversarial-test results, with the revisions made where mitigations failed.

Mode: light / standard / full
light
Annual adversarial test per high-demand system with published test batteries or an external tester.
standard
The security lead validates on change and contracts an external test yearly.
full
A recurring red-team programme across the estate, with validation automated.

Evidence

The treatment decisions and residual-risk acceptances; the validation and adversarial-test results; evidence of mitigations revised where they failed.