Third-Party and Customer Relationships - ISO 42001 Annex A Controls
ISO 42001 Annex A.10
AI systems rarely sit entirely within one organisation. Annex A.10 makes the relationships across the AI supply chain explicit and accountable.
ISO 42001 Annex A.10 - Third-Party and Customer Relationships Explained
Annex A.10 recognises that AI systems are typically built and used through chains of relationships - data providers, model developers, platform operators, system integrators, deployers and end users. The three controls together require the organisation to understand its role in the chain, manage its suppliers appropriately, and meet its customers' needs.
Control A.10.2 - Allocating responsibilities
The organisation must make sure responsibilities within the AI system life cycle are allocated between itself, its partners, suppliers, customers and third parties. The implementation guidance under Annex B.10.2 recognises that responsibilities can be split between parties providing data, parties providing algorithms and models, parties developing or using the AI system, and parties accountable to interested parties. The organisation should document all parties intervening in the AI system life cycle and their roles, and determine their responsibilities.
For organisations processing personal data through AI systems, the allocation often follows the data protection split between PII processors and PII controllers. ISO/IEC 29100 provides further guidance, and ISO/IEC 27701 provides the privacy management framework that integrates with ISO 42001.
Control A.10.3 - Suppliers
The organisation must establish a process to make sure its use of services, products or materials provided by suppliers aligns with its approach to the responsible development and use of AI systems. The implementation guidance recognises that organisations developing or using AI systems can use suppliers in many ways - from data sets to algorithms to whole AI systems delivered as products. The organisation should consider the type of supplier, what they supply, and the level of risk involved when determining selection criteria, contractual requirements and ongoing monitoring.
Where an AI system or component from a supplier does not perform as intended or causes impacts not aligned with the organisation's responsible AI approach, the organisation must require the supplier to take corrective action. The organisation can decide to work with the supplier to achieve this. The supplier should provide appropriate documentation related to the AI system as required for the deployer's own management system obligations.
Control A.10.4 - Customers
The organisation must make sure its responsible approach to the development and use of AI systems considers customer expectations and needs. Customer expectations can come from product or service requirements during a design or engineering phase, contractual requirements, or general usage agreements. One organisation can have many different types of customer relationships, each with different needs and expectations.
The organisation should understand where responsibility lies with the AI provider and where it lies with the customer, while still meeting the customer's needs and expectations. Where the use of the AI system by the customer creates risks, the organisation can treat the risks by giving the customer appropriate information so the customer can address the corresponding risks at their end.
The supply chain in practice
For an AI deployer using a third-party AI system, A.10.3 is the central control. The supplier assessment, contract terms, ongoing monitoring and incident handling for the AI supplier are documented and applied. For an AI provider supplying AI systems to others, A.10.4 is the central control. The customer needs and expectations are understood, the responsibility allocation is documented, and the necessary information is provided to the customer to support their own responsible use.
Most organisations sit somewhere on this chain rather than at one end. They use AI from upstream suppliers and may provide AI-enabled services to downstream customers. Annex A.10 applies in both directions.
The supplier control under A.10.3 requires more than the standard supplier assessment most organisations already operate. AI suppliers raise specific questions that generic supplier assessments often do not cover - training data sources, model evaluation methods, bias considerations, retention of customer data for further training, and the supplier's own approach to incident management and updates. Extending the existing supplier assessment to cover the AI dimension is more efficient than creating a parallel AI-specific assessment, but the AI questions need to be added.
The customer control under A.10.4 matters most for AI providers. The provider needs to understand what the customer expects to do with the AI system, where the customer's responsibility starts, and what information the customer needs to discharge their responsibility. The integration with the documentation under A.6.2.7 and the information for users under A.8.2 is direct.
When auditing Annex A.10, I look at the supplier register, the supplier assessment process, the customer register and the customer relationship records. For suppliers, I expect to see AI-specific questions in the assessment and AI-specific terms in the contracts. For customers, I expect to see clear documentation of what is provided, what the customer is responsible for, and how information flows in both directions.
The PII allocation is the area I look at most carefully. Where AI systems process personal data, the responsibility split between PII controllers and PII processors needs to be explicit and consistent with the data protection arrangements in ISO 27701 or the organisation's own privacy management framework.
The supplier assessment for the inspection AI vendor was an extension of our existing process. We added AI-specific questions on training data, model performance metrics, support response times and update procedures. The vendor was used to it - they have other ISO 42001 certified customers asking the same questions.
Practical Compliance Guidance
The supplier assessment process is the central operational mechanism for satisfying A.10.3, with the existing supplier assessment extended to cover AI-specific questions. The customer relationships are managed through the existing customer management arrangements, extended to cover the AI dimension where AI is part of the product or service.
The following alphaZ documents support compliance with ISO 42001 Annex A.10.
| alphaZ document | How to use it |
|---|---|
| ISO 42001 AI Management System Toolkit | The full toolkit containing the AI management system documentation including the supplier assessment template and supporting registers. |
| F-Q9 Supplier and Contractor Appraisal | The supplier appraisal form, extended to cover AI-specific questions for AI suppliers including training data, model performance, bias considerations, and update arrangements. |
| F-IMS40 AI Process Register | Records the AI systems within scope and the suppliers and customers associated with each, supporting the responsibility allocation under A.10.2. |
| F-IMS70 Annex A Controls | Records the Statement of Applicability including the A.10 controls with the implementation status and supporting evidence. |
Note - all the above files can be downloaded with an alphaZ subscription.
Frequently Asked Questions
UK Legislation
The following UK legislation is directly relevant to third-party and customer relationships involving AI systems. Organisations outside the UK should identify the equivalent legislation applicable in their jurisdiction.
