AI Risk vs ISMS Risk – Comprehensive Comparison

AI Risk vs ISMS Risk

Comprehensive Comparison

A Practical Guide for GRC & Cybersecurity Professionals

Date: April 2025

Version: v1.0

Prepared By: Peer Saheb Shaik

Peer Saheb Shaik

AI Risk vs ISMS Risk – Comprehensive Comparison

Table of Contents
Table of Contents.................................................................................................................................................. 2
1. Executive Summary......................................................................................................................................... 3
2. Introduction.......................................................................................................................................................3
3. Overview of Key Concepts............................................................................................................................. 3
3.1 AI Risk.............................................................................................................................................................................. 3
3.2 ISMS Risk (ISO 27001)..............................................................................................................................................4
3.3 Key Definitions............................................................................................................................................................. 4
4. Detailed Side-by-Side Comparison............................................................................................................. 6
5. How AI Risk and ISMS Risk Relate.............................................................................................................. 8
Example 1: Data Privacy.................................................................................................................................................. 8
Example 2: Access Control..............................................................................................................................................8
Example 3: Third-Party / Vendor Risk...................................................................................................................... 8
6. Gaps in Traditional ISMS When Dealing with AI Risk.......................................................................... 9
7. Real-World Use Cases................................................................................................................................... 10
Use Case 1: Banking - AI Fraud Detection Model............................................................................................. 10
Use Case 2: Healthcare - AI Diagnostic Tool....................................................................................................... 10
Use Case 3: HR / Recruitment - AI Resume Screening Tool.........................................................................11
8. Integrated Risk Management Approach................................................................................................ 12
8.1 Relevant Frameworks.............................................................................................................................................12
8.2 Practical Steps for Integration............................................................................................................................ 12
9. Recommended Controls Summary.......................................................................................................... 14
10. Roles and Responsibilities.......................................................................................................................14
11. Key Takeaways............................................................................................................................................. 16
12. Conclusion..................................................................................................................................................... 16
13. References & Further Reading................................................................................................................18

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AI Risk vs ISMS Risk – Comprehensive Comparison

1. Executive Summary
This document provides a structured, practical comparison between AI Risk and Information
Security Management System (ISMS) Risk, as defined by ISO/IEC 27001:2022. It is intended to
support CISOs, Chief Risk Officers, compliance leads, and Board-level decision-makers in
understanding how these two risk domains differ, where they overlap, and how to manage them
together.
AI adoption is accelerating across every sector. With it comes a new class of risks that traditional
security frameworks were not designed to address - from biased training data and hallucinating
models to opaque algorithmic decisions and AI supply chain vulnerabilities. At the same time, the
fundamentals of ISMS risk - protecting information confidentiality, integrity, and availability -
remain essential and non-negotiable.
Managing these risks in silos is no longer viable. This document presents the case for an integrated
risk management approach, drawing on ISO 27001, ISO 42001, the NIST AI Risk Management
Framework, and the EU AI Act. It includes a side-by-side comparison, real-world use cases, gap
analysis, and practical guidance to help organisations build a unified and resilient risk posture.

2. Introduction
The digital environment has never changed faster. Organisations across banking, healthcare, retail,
logistics, and government are deploying AI at scale - using machine learning models for fraud
detection, natural language processing for customer service, and algorithmic systems for hiring,
lending, and clinical diagnosis. According to McKinsey,A majority of organisations are now adopting
AI in at least one business function, and that number continues to rise.
This rapid adoption creates enormous value. But it also introduces a new and complex class of risks
that most existing governance frameworks were not built to handle. Traditional ISMS programmes,
anchored by ISO/IEC 27001, were designed for a world of deterministic systems - where data was
processed by known, predictable software. AI changes that fundamentally. Models learn from data,
evolve over time, and can produce unexpected or unexplainable outcomes. The risk profile changes
with every model update, every new training dataset, and every shift in the operational
environment.
This means that GRC and cybersecurity professionals now need to manage two distinct but
interconnected risk domains simultaneously. Understanding the difference between AI Risk and
ISMS Risk - and knowing where they converge - is not a theoretical exercise. It is a practical
necessity for anyone responsible for protecting their organisation in an AI-driven world.

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AI Risk vs ISMS Risk – Comprehensive Comparison

3. Overview of Key Concepts

3.1 AI Risk
AI risk refers to the potential for harm arising from the development, deployment, or operation of
artificial intelligence systems. It is not a single, static risk category - it is a broad and evolving set of
concerns that span technical, ethical, legal, and operational dimensions.
Key sources of AI risk include:
●​ Data risk: Training data that is biased, incomplete, mislabelled, or deliberately poisoned can
cause AI models to produce unfair, inaccurate, or harmful outputs.
●​ Model risk: Issues such as model drift (where a model's accuracy degrades as real-world
data diverges from training data), hallucinations (confident but incorrect outputs), and
overfitting can lead to poor or dangerous decisions.
●​ Algorithmic risk: Opaque, black-box algorithms can make decisions that are difficult to
challenge, audit, or explain - raising legal and ethical concerns particularly in regulated
sectors.
●​ Third-party AI risk: Organisations often rely on pre-trained models, AI APIs, and
open-source components from external providers. These introduce supply chain risks
around model provenance, data handling, and vendor dependency.
●​ Operational risk: AI systems in production require continuous monitoring. Without it,
performance degradation, output skew, or adversarial manipulation can go undetected.

For businesses, the impact of AI risk ranges from regulatory penalties (particularly under GDPR and
the EU AI Act) and reputational damage to flawed operational decisions, discriminatory outcomes,
and legal liability.

3.2 ISMS Risk (ISO 27001)

ISMS risk is the risk to the confidentiality, integrity, and availability (CIA) of information assets
within an organisation. ISO/IEC 27001:2022 provides the internationally recognised framework for
identifying, assessing, treating, and monitoring these risks through a systematic Information
Security Management System.
The ISMS risk framework covers three fundamental dimensions:
●​ People: Human error, insider threats, social engineering, and failure to follow security
policies.
●​ Process: Inadequate procedures, poor access governance, ineffective incident response, and
non-compliant vendor management.
●​ Technology: Unpatched software, misconfigured systems, weak encryption, and insufficient
network security controls.

ISO 27001:2022 includes 93 controls across four themes in Annex A: Organisational controls,
People controls, Physical controls, and Technological controls. These controls address areas such as
access management, cryptography, physical security, asset management, incident response, and
supplier relationships. ISMS risk is relatively structured - it follows known threat taxonomies and
applies a documented, auditable control framework.

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AI Risk vs ISMS Risk – Comprehensive Comparison

3.3 Key Definitions

Key Definitions
Risk: The potential for loss or harm resulting from a threat exploiting a vulnerability,
measured by its likelihood and impact.
Threat: Any circumstance or event - internal or external, deliberate or accidental - with the
potential to harm information assets or AI systems.
Vulnerability: A weakness in a system, process, model, or control that can be exploited by a
threat to cause harm.
Impact: The consequence or degree of harm that results if a risk event materialises -
including financial loss, reputational damage, regulatory penalty, or operational disruption.
Likelihood: The probability that a risk event will occur within a defined timeframe, based on
threat intelligence, historical data, and control effectiveness.

4. Detailed Side-by-Side Comparison

The table below provides a comprehensive comparison across ten key dimensions. Use this as a
reference tool when scoping risk assessments, designing governance structures, or briefing senior
leadership on the differences between AI and ISMS risk.

Aspect AI Risk ISMS Risk (ISO 27001)

Definition The potential for harm arising from The risk of adverse effects on the
the design, development, confidentiality, integrity, or
deployment, or use of AI systems - availability (CIA) of information
including models, data pipelines, and assets within an organisation.
AI-enabled applications.

Scope AI models, training data, inference People, processes, and technology

pipelines, third-party AI APIs, across the entire organisation -
automated decision-making covering all information assets
processes, and AI-generated outputs. regardless of whether AI is involved.

Source of Biased or poisoned training data, Human error, insider threats,

Risk model hallucinations, model drift, cyberattacks, software
opaque algorithms, adversarial vulnerabilities, misconfigured
inputs, third-party AI supply chain, systems, natural disasters, and
and lack of human oversight. supplier failures.

Nature of Dynamic and adaptive - AI risk can Relatively static and structured -
Risk evolve as models learn, data changes, risk categories and control mappings
or the operational environment

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AI Risk vs ISMS Risk – Comprehensive Comparison

Aspect AI Risk ISMS Risk (ISO 27001)

shifts. Risk profiles can change follow defined threat taxonomies and
without direct human intervention. are updated on a periodic basis.

Affected Product decisions, automated IT infrastructure, data storage, user

Areas recommendations, customer access, physical assets, software
interactions, credit scoring, hiring systems, communications, and
decisions, medical diagnoses, and any business continuity.
area where AI output drives action.

Governing ISO/IEC 42001, NIST AI RMF, EU AI ISO/IEC 27001:2022, NIST SP

Frameworks Act, OECD AI Principles, Singapore 800-37, SOC 2, PCI DSS, HIPAA
Model AI Governance Framework. Security Rule, NIST CSF.

Risk Data Science/AI Team, Chief AI CISO, IT Security Team, Compliance

Ownership Officer, Product Owner, CISO - Officer - primarily within the
shared across technical and business information security function, with
units. business unit accountability.

Real-World A fraud detection model flags A phishing email compromises

Examples legitimate customer transactions. A employee credentials. An unpatched
hiring AI rejects qualified candidates server is exploited by ransomware. A
due to biased training data. A chatbot third-party supplier suffers a data
produces false regulatory guidance breach exposing customer records.
(hallucination).

Risk Model validation and testing, Access control, encryption, patch

Treatment / explainability tools (XAI), bias audits, management, security awareness
Controls adversarial testing, continuous model training, incident response plans,
monitoring, human-in-the-loop vulnerability scanning, supplier due
oversight, AI governance policies. diligence.

Residual Risk Accept with documented justification Accept, mitigate, transfer, or avoid -
Handling and monitoring triggers; transfer via governed by the Statement of
AI-specific insurance clauses; Applicability (SoA) and risk
escalate to senior leadership when treatment plan under ISO 27001.
autonomous decisions carry high
impact.

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AI Risk vs ISMS Risk – Comprehensive Comparison

5. How AI Risk and ISMS Risk Relate

AI risk and ISMS risk are not mutually exclusive. In many areas they overlap significantly, and in
some cases an AI-related event will simultaneously trigger both an AI risk and an ISMS risk
response. Understanding where the two domains intersect is critical for building a coherent,
joined-up governance approach.
Key overlap areas include data privacy, access control, vendor and third-party risk, incident
response, and audit and compliance. The following three examples illustrate how AI systems
introduce new dimensions into classic ISMS risk categories.

Example 1: Data Privacy

ISMS risk addresses data privacy through controls such as data classification, encryption, and access
restrictions - primarily aimed at preventing unauthorised access or disclosure. ISO 27001 Annex A
includes supplier management and data handling controls aligned with GDPR.
AI introduces a layer that ISMS alone cannot address: a model trained on personal data can
inadvertently memorise and reproduce that data in its outputs. This is known as training data
leakage or membership inference. A user querying an AI system could, in principle, extract personal
information that was present in the training data - even if the data is not stored in an accessible
format. This is simultaneously a data privacy risk (ISMS) and an AI-specific model risk that requires
specialised controls such as differential privacy and output filtering.

Example 2: Access Control

Under ISO 27001, access control requires that users only have the permissions they need, and that
access to sensitive systems is managed, logged, and reviewed. This is a well-understood and
well-controlled area.
When an AI system is introduced, the access control perimeter expands significantly. New questions
arise: Who is permitted to query the model? Who can submit new training data or trigger
retraining? Who can view model outputs, and under what conditions? Who can modify the model
pipeline? Standard ISMS access control policies do not automatically address these dimensions. A
separate access governance framework specific to AI systems must be designed and integrated into
the existing ISMS controls.

Example 3: Third-Party / Vendor Risk

ISO 27001 requires organisations to assess and manage supplier risk, including security reviews,
contractual clauses, and monitoring of third-party access. This framework is effective for traditional
software suppliers and cloud providers.
AI changes the third-party risk landscape substantially. Organisations now rely on pre-trained
foundation models, open-source model weights, AI APIs, and third-party data annotation services.
The risk questions are different: Was the pre-trained model trained on clean, unbiased data? Has
the model been tampered with (model poisoning)? Does the AI API provider log all queries, raising
confidentiality concerns? These risks require AI-specific due diligence that goes beyond standard
vendor security questionnaires.

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AI Risk vs ISMS Risk – Comprehensive Comparison

6. Gaps in Traditional ISMS When Dealing with AI Risk

ISO 27001 is a robust and comprehensive standard - but it was designed before the widespread
adoption of machine learning and AI. The following areas represent gaps where traditional ISMS
controls are insufficient to address AI-specific risks:

Gap 1: Model Explainability

ISO 27001 has no controls requiring that automated systems be explainable or interpretable. In
regulated contexts - such as credit decisions, insurance underwriting, or medical diagnosis -
organisations are legally required to explain how automated decisions are made (e.g., GDPR Article
22). ISMS provides no mechanism to audit or govern the logic of AI models. ISO 42001 and the EU AI
Act begin to address this, but most ISMS implementations remain silent on explainability.
Gap 2: Algorithmic Bias and Fairness
ISMS risk focuses on security and operational outcomes - it does not cover fairness, discrimination,
or equity in automated decision-making. A hiring AI that systematically disadvantages candidates
from certain demographic groups represents a significant legal and ethical risk, but it falls entirely
outside the scope of ISO 27001 controls. Addressing algorithmic bias requires dedicated fairness
metrics, bias audits, and governance processes that sit outside the traditional ISMS framework.
Gap 3: AI Supply Chain Integrity
Standard supplier risk controls under ISO 27001 cover data processing agreements and security
assessments - but they do not address the unique risks of AI supply chains. These include the
integrity of pre-trained model weights, the provenance and quality of third-party training data, the
security of model registries, and the risk of adversarial contamination in open-source AI
components. The AI supply chain requires its own risk taxonomy and control set.
Gap 4: Model Drift and Continuous Behavioural Monitoring
ISO 27001 requires periodic risk reviews and continuous monitoring of security events. However, it
does not include any concept of monitoring the behavioural outputs of AI models over time. Model
drift - where a model's performance degrades silently as the real world diverges from training data
- is invisible to standard ISMS monitoring tools. Detecting and responding to drift requires
purpose-built ML monitoring infrastructure and defined performance thresholds, none of which are
covered by ISO 27001.
Gap 5: Autonomous Decision-Making Governance
ISMS risk management assumes that humans are ultimately responsible for decisions and
outcomes. AI systems increasingly make fully autonomous decisions - in fraud detection,
algorithmic trading, medical triage, and content moderation - without real-time human review. ISO
27001 has no controls governing when human oversight is required, how to implement kill switches
for autonomous systems, or how to assign accountability when an AI decision causes harm. These
questions are addressed by the EU AI Act and the NIST AI RMF, but require deliberate integration
into existing governance frameworks.

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AI Risk vs ISMS Risk – Comprehensive Comparison

7. Real-World Use Cases

Use Case 1: Banking - AI Fraud Detection Model
A large retail bank deploys a machine learning model to detect fraudulent transactions in real time.
The model processes millions of transactions daily and automatically blocks those flagged as
suspicious.

Risk Type Risk Description and Implications

AI Risk The model was trained on historical fraud data that over-represents
certain transaction patterns. As a result, it has a higher false positive rate
for transactions from specific geographic regions and customer
demographics. Legitimate customers are having their payments declined,
causing reputational damage, customer complaints, and potential
regulatory scrutiny under consumer protection laws. Additionally, the
model has not been retrained in six months and may have drifted from
current fraud patterns.

ISMS Risk The fraud model's decision logs contain detailed customer transaction
data. Insufficient access controls mean that a broader group of
employees than necessary can view flagged transaction records, creating
a data privacy risk under GDPR. There is also no documented incident
response process for scenarios where the model causes a widespread
service disruption - for example, if the model is manipulated by an
adversarial attack to block all transactions above a certain value.

Use Case 2: Healthcare - AI Diagnostic Tool

A hospital network deploys an AI-powered radiology tool that analyses chest X-rays and flags
potential signs of lung cancer for radiologist review. The system processes hundreds of scans per
day across multiple hospital sites.

Risk Type Risk Description and Implications

AI Risk The model was trained primarily on data from adult male patients and
performs significantly less accurately on scans from female patients and
patients under 40. This demographic bias means certain patient groups
receive lower-quality diagnostic support - a direct patient safety risk.
There is no mechanism for radiologists to understand why the model
flagged or did not flag a particular scan, making it difficult to challenge or
override the system's conclusions in edge cases.

ISMS Risk The diagnostic system processes highly sensitive patient health data
(special category data under GDPR). The system is accessed by
radiologists across multiple hospital sites via a cloud-hosted interface. A

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AI Risk vs ISMS Risk – Comprehensive Comparison

Risk Type Risk Description and Implications

security assessment reveals that data in transit between hospital sites

and the cloud provider is insufficiently encrypted, and that the cloud
provider's data residency does not comply with national health data
sovereignty requirements. A data breach involving patient health records
would carry severe regulatory, reputational, and legal consequences.

Use Case 3: HR / Recruitment - AI Resume Screening Tool

A multinational company deploys an AI tool to screen CVs and shortlist candidates for interviews.
The tool ranks applicants based on a model trained on the profiles of previously successful hires.

Risk Type Risk Description and Implications

AI Risk Because the model was trained on historical hire data that reflects past
biases, it systematically down-ranks CVs from women applying to
technical roles and candidates from certain universities. This is a
textbook case of algorithmic bias reproducing and amplifying historical
discrimination. The organisation faces legal exposure under equality
legislation and reputational risk if the bias is reported by affected
candidates or identified in a regulatory audit.

ISMS Risk The recruitment tool ingests and processes candidate personal data -
names, contact details, work history, and educational background - all of
which is subject to GDPR. The vendor providing the AI tool retains
candidate data on its own servers and uses it to improve its model across
all clients, potentially sharing data in ways not disclosed to candidates.
There is no data processing agreement (DPA) in place. This represents
both a GDPR compliance failure and an ISO 27001 supplier management
control gap.

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AI Risk vs ISMS Risk – Comprehensive Comparison

8. Integrated Risk Management Approach

The most resilient organisations do not treat AI risk and ISMS risk as separate workstreams - they
integrate them within a unified governance architecture. The following frameworks and practical
steps provide a roadmap for achieving this.

8.1 Relevant Frameworks

●​ ISO/IEC 27001:2022 - Provides the ISMS foundation: risk assessment methodology, control
framework (Annex A), and continuous improvement cycle. The starting point for
information security governance.
●​ ISO/IEC 42001:2023 - The AI Management System (AIMS) standard. Designed to
complement ISO 27001, it addresses AI-specific governance including transparency, bias
management, impact assessments, and AI lifecycle controls.
●​ NIST AI Risk Management Framework (AI RMF 1.0) - A voluntary framework structured
around four core functions: Govern (establish accountability), Map (identify AI context and
risk), Measure (analyse and assess risk), and Manage (respond to and monitor risk). Highly
practical for operationalising AI risk management.
●​ EU AI Act (2024) - A binding regulatory framework that classifies AI systems by risk level
(Unacceptable, High, Limited, Minimal) and imposes specific requirements on providers and
deployers of high-risk AI systems, including in healthcare, financial services, and
employment.
●​ Unified Risk Register - A single, consolidated risk register that captures both ISMS and AI
risks under a common risk taxonomy, enabling consistent prioritisation, treatment tracking,
and reporting to senior leadership.

8.2 Practical Steps for Integration

●​ Extend your risk assessment methodology. Adapt your existing ISO 27001 risk assessment
process to include AI-specific risk categories: data quality and bias, model performance and
drift, algorithmic transparency, AI supply chain, and autonomous decision-making
governance. Use the NIST AI RMF's Map function as a guide.
●​ Conduct an AI asset inventory. Identify all AI systems in use across the organisation -
including third-party AI APIs and embedded AI in software products. Classify each by risk
level using the EU AI Act taxonomy. This forms the foundation for proportionate governance.
●​ Align control frameworks. Map the controls from ISO 42001 and the NIST AI RMF against
your existing ISO 27001 control set. Identify gaps and add AI-specific controls to your
Statement of Applicability (SoA). Avoid duplication by creating cross-referenced control
mappings.
●​ Establish an AI Governance Committee. Create a cross-functional body - including the CISO,
CRO, Data Science Lead, Legal/Compliance, and a business representative - with oversight
of AI risk. Define escalation paths, risk appetite thresholds, and reporting cadence to the
Board.
●​ Implement continuous AI monitoring. Deploy ML monitoring tools to track model
performance, detect drift, flag anomalous outputs, and alert on adversarial inputs. Integrate
alerts into your existing SIEM and incident response workflow.
●​ Run integrated training and awareness. Ensure that both ISMS and AI risk concepts are
covered in security awareness programmes. Data scientists need to understand ISMS

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AI Risk vs ISMS Risk – Comprehensive Comparison

principles; security teams need to understand AI risk. Bridge the skills gap through joint
training and internal knowledge sharing.

9. Recommended Controls Summary

The table below summarises recommended controls across the key areas where AI risk and ISMS
risk intersect or require dedicated attention.

Control Area Recommended Action

Data Governance Establish data classification, retention, and lineage policies that
extend to AI training datasets. Validate data sources for accuracy,
completeness, and fairness before use in model development.

Model Risk Implement a formal model validation process covering

pre-deployment testing, bias assessments, performance benchmarks,
and periodic re-validation after significant data changes.

Access Control Apply least-privilege principles to AI systems - restrict who can

query models, retrain models, view outputs, or access training data.
Enforce MFA and privileged access management.

Vendor Risk Conduct AI-specific due diligence on third-party AI providers -

assess model transparency, data handling practices, API security, SLA
terms, and right-to-audit clauses.

Incident Response Extend the existing IR plan to cover AI-specific scenarios: model
failure events, adversarial attacks, hallucination-driven decisions,
and AI-caused data exposure.

Audit & Logging Maintain comprehensive logs of AI model inputs, outputs, and
decision points. Ensure audit trails are tamper-resistant and support
regulatory review, particularly for high-impact decisions.

Bias & Fairness Run regular bias audits on models used in hiring, lending, healthcare,
and other high-stakes domains. Use fairness metrics (demographic
parity, equal opportunity) and document outcomes.

Explainability Require that AI systems used in regulated or high-impact contexts

can produce human-readable explanations for their decisions. Use
XAI tools (SHAP, LIME) and document model logic for audit
purposes.

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AI Risk vs ISMS Risk – Comprehensive Comparison

10. Roles and Responsibilities

Effective risk management depends on clear ownership. The table below defines responsibilities for
both AI risk and ISMS risk across key organisational roles.

Role AI Risk Responsibility ISMS Risk Responsibility

CISO Oversees AI security strategy, Owns the ISMS programme, drives

ensures AI risk is integrated into the ISO 27001 certification, and reports
security programme, and escalates on information security posture to
high-impact AI risks to the Board. senior leadership.

CRO / Risk Ensures AI risks are captured in the Sets the overall risk appetite for
Officer enterprise risk register and that risk information security and oversees
appetite is defined for AI-driven risk treatment decisions.
decisions.

Data Science / Primary owners of model risk - Responsible for securing AI

AI Team responsible for model design, development environments,
testing, bias evaluation, monitoring, protecting training data, and
and documentation of AI systems. following secure coding practices.

IT Security Supports secure deployment of AI Implements and maintains ISMS

systems, monitors AI-related technical controls - firewalls,
security events, and enforces access endpoint protection, patch
controls on AI infrastructure. management, and SIEM monitoring.

Compliance Tracks AI regulatory obligations (EU Manages ISO 27001 compliance,

Officer AI Act, GDPR for automated coordinates internal audits, and
decisions) and ensures AI practices liaises with external certifying
align with legal requirements. bodies.

Business Unit Accountable for AI systems Responsible for information assets

Owner deployed within their business in their domain, ensures staff
function - ensures appropriate use, comply with security policies, and
monitors outcomes, and escalates participates in risk assessments.
concerns.

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AI Risk vs ISMS Risk – Comprehensive Comparison

11. Key Takeaways

If you only have two minutes, here is what matters most from this document:

Quick Reference Summary

●​ AI Risk and ISMS Risk are different in origin, scope, and nature - but they overlap
significantly in areas such as data privacy, access control, vendor risk, and incident
response. Managing them as separate silos will leave critical gaps.
●​ ISO 27001 alone is not sufficient for AI risk. It does not cover model explainability,
algorithmic bias, model drift, AI supply chain integrity, or autonomous decision-making
governance.
●​ ISO 42001 and the NIST AI RMF are designed to complement ISO 27001 - not replace
it. Use all three together to build a comprehensive governance architecture.
●​ The EU AI Act introduces binding obligations for organisations deploying or developing
high-risk AI systems. Compliance requires understanding your AI asset inventory and
classifying each system by risk level.
●​ A unified risk register that captures both AI and ISMS risks under a common taxonomy
is the most practical starting point for integration. It enables consistent prioritisation
and a single view of risk exposure for senior leadership.
●​ Risk ownership must be explicit. AI risk is not owned solely by the Data Science team,
and ISMS risk is not owned solely by IT Security. Both require shared accountability
across technical, compliance, legal, and business functions.
●​ Continuous monitoring is essential for AI risk. Unlike traditional security controls that
are set and reviewed periodically, AI models require real-time behavioural monitoring
to detect drift, bias escalation, and adversarial manipulation.
●​ Start with what you have. Extend your existing ISMS risk assessment, SoA, and incident
response plan to cover AI-specific scenarios. You do not need to rebuild your
governance programme from scratch.

12. Conclusion
The era of managing AI risk and information security risk as separate disciplines is over. As AI
systems become embedded in core business processes - from credit decisioning and healthcare
diagnostics to supply chain optimisation and talent acquisition - the risks they introduce are
inseparable from the broader information security and governance landscape.
Organisations that rely solely on ISO 27001 to govern their risk environment will encounter blind
spots that expose them to regulatory penalty, operational failure, and reputational harm. At the
same time, building an entirely separate AI risk programme from scratch is inefficient and creates
unnecessary duplication.
The answer is integration. By aligning ISO 27001 with ISO 42001, the NIST AI RMF, and the EU AI
Act, organisations can build a unified, proportionate, and sustainable risk management architecture

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AI Risk vs ISMS Risk – Comprehensive Comparison

that covers both domains. The starting point is not complexity - it is clarity: know your AI assets,
extend your existing risk processes, assign clear ownership, and monitor continuously.
The organisations that get this right will not just be more secure - they will be more trusted, more
resilient, and better positioned to harness the transformative potential of AI responsibly.

13. References & Further Reading

The following standards, frameworks, and publications were referenced in the preparation of this
document and are recommended for further reading:

●​ ISO/IEC 27001:2022 - Information Security, Cybersecurity and Privacy Protection -

Information Security Management Systems - Requirements. International Organisation for
Standardisation (ISO). Available at: [Link]
●​ ISO/IEC 42001:2023 - Information Technology - Artificial Intelligence - Management
System. International Organisation for Standardisation (ISO). Available at: [Link]
●​ NIST AI Risk Management Framework (AI RMF 1.0). National Institute of Standards and
Technology, U.S. Department of Commerce. January 2023. Available at:
[Link]/system/files/documents/2023/01/26/AI%20RMF%[Link]
●​ EU AI Act (Regulation (EU) 2024/1689). European Parliament and Council of the European
Union. June 2024. Available at: [Link]
●​ ENISA AI Threat Landscape Report. European Union Agency for Cybersecurity (ENISA).
Latest edition available at: [Link]
●​ NIST SP 800-37 Rev. 2 - Risk Management Framework for Information Systems and
Organisations. National Institute of Standards and Technology. December 2018. Available at:
[Link]​

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