Framework overlap

Does ISO/IEC 38500:2024 cover ISO/IEC 42001:2023?

You hold ISO/IEC 38500:2024 and have been told to do ISO/IEC 42001:2023. Here is how much overlaps, control by control.

37% of ISO/IEC 42001:2023 you already have

ISO/IEC 38500:2024 already covers about 37% of ISO/IEC 42001:2023, leaving 49 of 78 controls as genuinely new work.

Already covered 19 Likely covered 10 New work 49

What is genuinely new work

Nothing in ISO/IEC 38500:2024 reaches these. This is the list to scope.

A.10.2
Confidentiality obligations of personnel
A.10.3
Restriction of creation of hardcopy material
A.10.4
Control and logging of data restoration
A.2.2
AI policy
A.2.3
Alignment with other organizational policies
A.2.4
Review of the AI policy
A.3.3
Reporting of concerns
A.4.2
Resource documentation
A.4.4
Tooling resources
A.4.5
System and computing resources
A.4.6
Human resources
A.5.2
AI system impact assessment process
A.5.3
Documentation of AI system impact assessments
A.5.4
Assessing AI system impact on individuals or groups
A.5.5
Assessing societal impacts of AI systems
A.6.1.1
Objectives for responsible development of AI systems
A.6.1.2
Processes for responsible AI system design and development
A.6.2.2
AI system requirements and specification
A.6.2.3
Documentation of AI system design and development
A.6.2.4
AI system verification and validation
A.6.2.5
AI system deployment
A.6.2.6
AI system operation and monitoring
A.6.2.7
AI system technical documentation
A.6.2.8
AI system event logging
A.7.2
Data for development and enhancement of AI systems
A.7.4
Quality of data for AI systems
A.8.2
System documentation and information for users
A.8.3
External reporting
A.8.5
Information for interested parties
A.9.2
Processes for responsible use of AI systems
A.9.3
Objectives for responsible use of AI system
A.9.4
Intended use of the AI system
10.1
Continual improvement
10.2
Nonconformity and corrective action
4.1
Understanding the organization and its context
4.2
Understanding the needs and expectations of interested parties
4.3
Determining the scope of the management system
5.1
Leadership and commitment
6.1
Actions to address risks and opportunities
6.1.4
AI system impact assessment
6.2
Objectives and planning to achieve them
7.5.3
Control of documented information
8.1
Operational planning and control
8.7
Third-party and customer relationships
9.1
Monitoring, measurement, analysis and evaluation
A.10
Third-party and customer relationships
A.5
Assessing impacts of AI systems
A.6
AI system life cycle
A.8
Information for interested parties of AI systems
Show the 29 you already have
4.4
Management system
5.2
Policy
6.1.2
Risk assessment
6.1.3
Risk treatment
7.1
Resources
7.2
Competence
7.3
Awareness
7.4
Communication
7.5
Documented information
7.5.2
Creating and updating
8.4
Data for AI systems
8.6
Use of AI systems
9.2
Internal audit
9.3
Management review
A.2
Policies related to AI
A.3
Internal organization
A.4
Resources for AI systems
A.7
Data for AI systems
A.9
Use of AI systems
A.3.2
AI roles and responsibilities
A.4.3
Data resources
A.7.3
Acquisition of data
A.7.5
Data provenance
A.7.6
Data preparation
A.8.4
Communication of incidents
5.3
Roles, responsibilities and authorities
8.2
AI system impact assessment
8.3
AI system lifecycle management
8.5
Information for interested parties of AI systems

How this is calculated

Already covered means a mapping runs from a control in ISO/IEC 38500:2024 to that control. Likely covered means no direct mapping exists but both frameworks map to the same control in a third standard. New work means neither. We keep those separate rather than adding them into one friendlier number, because blending them would present a two-hop inference as a verified fact.

Coverage is not symmetric. Run it the other way and you will get a different number; both are correct.

From 332,959 cross-framework control mappings across 723 frameworks, 531 of them verified against their source documents. It does not tell you that you are compliant: a mapped control means the two standards ask for the same thing, not that you have done it.

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