Overview & importance

Defining context & boundaries is the first step in building an AI Management System (AIMS). It ensures clarity on the organisation’s purpose, AI portfolio, stakeholder expectations and constraints that shape risk management and governance. Auditors verify this to understand what your AIMS actually covers and what is excluded.

Internal context factors

• Business model and AI objectives (e.g., automated customer support, predictive inventory management).
• AI systems and platforms in use — foundation models, custom LLMs, RAG pipelines, MLOps frameworks.
• Existing management systems (ISO 27001, 27701, 9001, 14001 integration points).
• Roles and competence availability — AIMS Manager, Data Steward, Privacy Officer, Oversight Operators.
• Infrastructure — data centres, cloud regions, compute clusters, AI toolchain dependencies.

External context factors

• Legal & regulatory environment (EU AI Act, UK AI Principles, ICO Guidance, Digital Services Act).
• Market conditions and stakeholder expectations for trustworthy AI.
• Technological trends and emerging AI risks (e.g., deepfake content, model autonomy).
• Supply-chain dependencies — model APIs, dataset providers, cloud vendors.

Stakeholders & requirements

• Customers and end users — accuracy, fairness, explainability expectations.
• Regulators and authorities — conformance with AI Act obligations and sector rules.
• Suppliers — obligation to provide transparency and bias/security controls.
• Employees — training, oversight duties, and AI ethical use policies.
• Investors — governance and accountability metrics in ESG reporting.

Scope & boundaries definition

Define what is included in the AIMS scope and justify any exclusions. Auditors must be able to trace why each decision was made and whether it affects risk coverage.

• Included: All AI systems used in decision-making or producing outputs affecting humans or the environment.
• Excluded: Experimental sandboxes, purely offline model research, non-automated analytical tools (with justification).
• Geographic scope: Specify regions covered (EU, UK, third countries) and data residency arrangements.
• Organisational scope: Legal entities, subsidiaries, joint ventures covered by the certificate.

Interfaces & dependencies

• List interfaces between AIMS and other management systems (27001, 9001 etc.).
• Identify shared controls (e.g., access management, incident response, supplier governance).
• Document data flows and handoffs between teams (e.g., ML Engineering → Oversight → Legal).

Maintaining & reviewing context

• Review context annually and after major business, technology or regulatory change.
• Update AIMS Manual and Scope Statement with version control and approval sign-off.
• Communicate changes to auditors before surveillance or recertification.

Tools & templates

Organisation: Zen AI Governance UK Ltd  
Purpose: Development and operation of AI-based compliance and governance solutions.  
Scope: All AI systems deployed for client advisory and internal decision support within the UK & EU.  
Exclusions: Prototype models in sandbox environments (not customer-facing).  
Interfaces: ISO 27001 (ISMS), ISO 27701 (PIMS).  
Version: 1.2  |  Approved by: Authorising Officer  |  Date: 2025-11-08
  

Worked examples

• Example 1 — AI Product Company: Scope covers model development & deployment; excludes customer integration environments.
• Example 2 — Retail Enterprise: Scope covers AI for logistics & forecasting; excludes marketing experiments without personal data.

Common pitfalls & mitigation

• Unclear scope: ambiguous inclusions → define systems explicitly in AIMS Manual.
• Missing context updates: review quarterly or after org change.
• No stakeholder mapping: maintain stakeholder register with expectations and requirements.
• Audit mismatch: ensure scope on certificate matches AIMS Manual exactly.

Implementation checklist

• Context analysis documented (internal & external).
• Stakeholders and requirements identified & updated annually.
• Scope Statement approved & communicated.
• Exclusions justified and recorded.
• Version control applied to AIMS Manual & Scope Statement.

Glossary

• AIMS: AI Management System (ISO/IEC 42001).
• Scope Statement: formal document defining coverage & boundaries of AIMS.
• Stakeholder Register: list of parties with AI governance interests or obligations.

© Zen AI Governance UK Ltd • Regulatory Knowledge • v1 08 Nov 2025 • This page is general guidance, not legal advice.