Policy, provenance and guardrails an auditor can follow.
Assurance proves a system is safe once. Governance proves it stays safe, with the paperwork to show it. Four fixed-price engagements, $3,900 to $8,900.
Readiness here, certification from the audit body. MetaMinds does gap assessment, readiness, control design and evidence preparation; the ISO/IEC 42001 certificate is issued by an accredited certification body and a SOC 2 report by a licensed CPA firm, each after its own audit you commission separately.
Six instruments run through this page and four of them are law: EU AI Act, GDPR, DPDP Act and HIPAA. ISO/IEC 42001 and NIST AI RMF are voluntary standards. All six name a risk assessment and a designated role, and each asks for different contents. Of the 12 provisions cited, 10 were read in full at the instrument’s own primary surface on 15 September 2026; the other two are ISO/IEC 42001 clauses read by title only, because that standard’s clause text is not public. See the provision for each.
Dates under the EU AI Act as amended by Regulation (EU) 2026/1744, the Digital Omnibus on AI, in force since 27 July 2026. Much indexed guidance still states the pre-Omnibus schedule, so check the date on anything you read, including this page. Verified 2 September 2026.
Two things all six instruments name.
The EU AI Act, ISO/IEC 42001, NIST AI RMF, GDPR, DPDP and HIPAA, side by side
The EU AI Act cells apply to high-risk systems only, from 2 Dec 2027 or 2 Aug 2028; the DPDP cells, from May 2027. The four instruments not marked voluntary are law.
Risk assessment
6/6instruments name it
5 read at provision text
Designated role
6/6instruments name it
5 read at provision text
Provisions read in full
10/12at the instrument’s own primary surface
2 read by clause title only, all on 15 Sep 2026
Every cell in full: the provision, what it asks for, and who it binds
Where each of six instruments names a risk assessment and a designated role, by provision, in the instrument’s own words.
EU AI Act
LawRegulation (EU) 2024/1689
- Risk assessment
- Art. 9(1)a risk management system, established, implemented, documented and maintained.Binds providers of high-risk systems, through Art. 16(a).
- Designated role
- Art. 26(2)human oversight assigned to natural persons with the necessary competence, training and authority.Binds deployers of high-risk systems.
High-risk duties apply from 2 Dec 2027 or 2 Aug 2028.
ISO/IEC 42001
VoluntaryISO/IEC 42001:2023
- Risk assessment
- Clause 8.2Titled “AI risk assessment”. Title read, text not.
- Designated role
- Clause 5.3Titled “Roles, responsibilities and authorities”. Title read, text not.
NIST AI RMF
VoluntaryNIST AI 100-1, January 2023
- Risk assessment
- MAP 5.1the likelihood and magnitude of each identified impact, identified and documented.
- Designated role
- GOVERN 2.1roles and responsibilities for mapping, measuring and managing AI risks, documented.
GDPR
LawRegulation (EU) 2016/679
- Risk assessment
- Art. 35(1)an assessment of the impact of the processing on the protection of personal data, before it starts.Where processing is likely to result in a high risk.
- Designated role
- Art. 37(1)a designated data protection officer.In the three cases Art. 37(1) lists.
DPDP Act
LawAct 22 of 2023
- Risk assessment
- s. 10(2)(c)(i)a periodic Data Protection Impact Assessment.Binds Significant Data Fiduciaries only.
- Designated role
- s. 10(2)(a)an appointed Data Protection Officer.Binds Significant Data Fiduciaries only.
These sections in force from May 2027.
HIPAA
Law45 CFR Part 164
- Risk assessment
- 45 CFR 164.308(a)(1)(ii)(A)a risk analysis, an accurate and thorough assessment of the potential risks and vulnerabilities to electronic protected health information.
- Designated role
- 45 CFR 164.308(a)(2)an identified security official.
- Provision text read
- Only in some cases, or not yet in force
- Clause title read, text not
Read this as where we traced a provision, not as a finding that any system complies.
Every provision, the surface it was read at and how
- Regulation (EU) 2024/1689: EUR-Lex, the Official Journal text
- https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401689Headless Chromium, HTTP 202, 588,616 characters. Amendments checked twice against Regulation (EU) 2026/1744 and the EUR-Lex record page: nothing amends Art. 9, 16 or 26.
- ISO/IEC 42001:2023: ISO Online Browsing Platform, the public part
- https://www.iso.org/obp/ui/en/#iso:std:iso-iec:42001:ed-1:v1:enHeadless Chromium, HTTP 200. The public contents list stops at two levels, so two clause titles were read and no clause text was. The Foreword is the source for voluntary.
- NIST AI 100-1, January 2023: NIST AI Resource Center, the AI RMF playbook
- https://airc.nist.gov/AI_RMF_Knowledge_Base/Playbook/GovernHeadless Chromium, HTTP 200, subcategory text taken from textContent. Not read as a PDF, and no page number in NIST AI 100-1 is claimed: the PDF text layer could not be decoded.
- Regulation (EU) 2016/679: EUR-Lex, the consolidated text
- https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679Headless Chromium, HTTP 200. Chapter V, Arts. 44 to 46, was read in the same capture for the data-residency answer on this page. The record page lists corrigenda and two proposals, no adopted amendment.
- Act 22 of 2023: Gazette of India, the print hosted by MeitY, and the e-Gazette
- https://www.meity.gov.in/static/uploads/2024/06/2bf1f0e9f04e6fb4f8fef35e82c42aa5.pdfHTTP 200 in a browser context, text taken from the PDF stream. Commencement from G.S.R. 843(E) of 13 Nov 2025, eighteen months on, which is why the date reads May 2027 and names no day.
- 45 CFR Part 164: eCFR versioner API, as of 10 Sep 2026
- https://www.ecfr.gov/api/versioner/v1/full/2026-09-10/title-45.xml?part=164§ion=164.308HTTP 200. The API is used because the eCFR web page redirects a headless browser to a bot check. The date in the path is what as of 10 Sep 2026 means.
SourceEvery provision opened 15 Sep 2026 at its own primary surface, no mirror: EUR-Lex, the ISO Online Browsing Platform, the NIST AI Resource Center, the Gazette of India and the eCFR versioner API. Ten were read in full; the two ISO/IEC 42001 clauses were read by title only, because that standard's clause text is not public. The URL, the method and the status per instrument are in the evidence record above.
What we produce against them
- EU AI Act
- Readiness assessment, $4,900: an inventory, a written classification per system, and the transparency gaps ranked against the dates.Read the Article 50 briefing
- ISO/IEC 42001 and NIST AI RMF
- Both priced below. NIST supplies the risk method and ISO/IEC 42001 the management system; they complement each other.See both engagements priced
- GDPR, DPDP Act 2023 and HIPAA
- Where personal data or PHI reaches prompts, embeddings, caches, logs and evaluation sets, which copies you can delete, and where the agreements stop.See how we handle data
Three parts, and the third is the only one that runs by itself.
- 01
Policy
One pass, ending at a personWhat you wrote down, and the first artifact an auditor asks for.
- AI use policy
- What staff may put into which system, per data class.
- Approval and exception paths
- Who signs off a new system, and the documented route around a rule.
- 02
Provenance
One pass, recorded at every step, and the record leaves with the fileWhere every input came from, and whether an output traces back to it.
- Training-data attestation
- What the system was trained or tuned on, and what it was not.
- Content credentials
- A signed provenance record attached to the generated file, so its origin travels with it.
- 03
Guardrails
A closed loop, and it runs on every request without youControls that run whether or not anyone is watching. A sentence in a prompt is a preference, not a control.
- Refusal and escalation
- What the system does at the edge of what it supports, and which human it hands to.
- Red-teaming
- Adversarial testing, run apart from the team that built the system.
Our own hallucination gate, rubric and limits included: how we hold hallucination under two percent.
Four governance engagements, every price and duration fixed.
A deposit reserves the start week and the balance is invoiced on delivery. No scoping fee.
- T2-08Start here2 weeks
Agent governance review
Kill switches, audit trails, human-in-the-loop boundaries and model change control, including where a stop control is missing.
Pick this whenAgents are already running in production and nobody has written down who can stop them.
$7,900fixed price, $1,400 depositBook Agent governance review, $7,900 - T2-062 weeks
NIST AI RMF alignment review
Govern, Map, Measure and Manage, applied to the systems you actually run.
Pick this whenYou need a risk method and have no framework in place to hang one on.
$7,500fixed price, $1,400 depositBook NIST AI RMF alignment review, $7,500 - T2-052 to 3 weeks
ISO/IEC 42001 gap assessment
Your position against the standard, control by control, and the evidence an external auditor will ask for.
Pick this whenISO/IEC 42001 is decided and you need your position against it, control by control.
$8,900fixed price, $1,500 depositBook ISO/IEC 42001 gap assessment, $8,900 - T2-091 week
Attestation readiness scoping
Scope, observation window, control gaps, internal cost and a realistic date for SOC 2 or ISO/IEC 42001, before you commit to either.
Pick this whenThe choice between SOC 2 and ISO/IEC 42001 is still open.
$3,900fixed price, $900 depositBook Attestation readiness scoping, $3,900
Each bar is that engagement’s price against $8,900, the highest of the four. The full catalog is on the assurance page.
Stated plainly
- We do not give legal advice
- Anything with legal effect belongs with counsel qualified in the relevant jurisdiction.
- We do not guarantee compliance
- No consultancy can.
The seven questions, and what a defensible answer contains.
Drawn from published 2026 AI procurement and CISO checklists. Grade your own answers before someone else does.
- 01How is the model hosted?
Name the posture and the contract behind it: a vendor API, a dedicated tenancy in a named cloud region, or self-hosted weights you control.
Record it per system, since hosting decides who can read the prompt.
- 02What training opt-outs apply?
Per provider and per tier, cite the executed contract clause and its effective date.
Tiers of one product can carry different training terms, and a settings screenshot is not evidence.
- 03How are agent identities scoped?
Each agent has its own identity, its own credentials and a written list of permitted actions, not the session of the human who triggered it.
Name what one compromised step can reach.
- 04Where is data residency?
A region, a lawful basis and a subprocessor list per data category: prompts, documents, embeddings, caches, logs and evaluation sets can sit apart.
Under GDPR, a transfer to a third country also needs a Chapter V basis, such as an adequacy decision or appropriate safeguards.
- 05What audit trail exists?
One recording the input, the retrieved context, the model and version, the decision and any human override, timestamped and kept long enough to answer a complaint.
- 06How is the kill switch operated?
Name who may stop the system, the control they use, how long it takes, and when it was last exercised.
An untested stop control is an assumption written in the present tense.
- 07What compliance evidence is produced?
Artifacts, not assurances: an AI system inventory, a written risk classification per system, model and system cards, a risk register with named owners, evaluation results with a method attached, and an ISO/IEC 42001 control mapping an external auditor can test.
Twenty more questions: ISO/IEC 42001 readiness, the EU AI Act crosswalk, what a gap assessment produces, and who the six instruments actually bind
Every answer here is the same string this page puts in its structured data, so a person and an answer engine read the identical text. Open one to read it.
What does an ISO/IEC 42001 gap assessment produce?
A control-by-control gap list against the standard, an evidence index naming the artifact that satisfies each control and the person who maintains it, and a remediation sequence ordered by what an external auditor will ask for first. It is readiness work: $8,900, 2 to 3 weeks. Certification against ISO/IEC 42001 comes from an accredited certification body, not from us.
Who issues ISO/IEC 42001 certification and a SOC 2 report?
Certification against ISO/IEC 42001 comes from an accredited certification body, and a SOC 2 report from a licensed CPA firm, each after its own audit that you commission and pay for directly. What MetaMinds does is gap assessment, readiness, control design and evidence preparation, which is the work that happens before either of them and largely determines how either goes.
How long does ISO/IEC 42001 readiness take?
The gap assessment itself is 2 to 3 weeks. How long remediation takes after it depends on how many controls have no evidence behind them, which is what the gap list counts, so it is quoted once that list exists rather than before. The certification audit is scheduled by an accredited certification body, so we do not quote a date for it.
Does ISO/IEC 42001 certification satisfy the EU AI Act?
No instrument substitutes for another. ISO/IEC 42001:2023 is a voluntary standard; the EU AI Act is law. They overlap rather than coincide: clause 8.2 is titled AI risk assessment and Article 9(1) requires a risk management system for high-risk systems, and the two ask for different contents. A management system built to ISO/IEC 42001 is evidence toward the Act, not compliance with it. Anything with legal effect belongs with counsel qualified in the relevant jurisdiction.
What is an EU AI Act to ISO/IEC 42001 crosswalk?
A provision-by-provision map of where two instruments ask for the same artifact, so one piece of evidence can answer both. The crosswalk published on this page covers two artifacts, a risk assessment and a designated role, across six instruments: the EU AI Act, ISO/IEC 42001, the NIST AI RMF, GDPR, the DPDP Act 2023 and HIPAA. Each cell names the provision, and says whether we read its text or only its clause title.
When do the EU AI Act high-risk obligations apply?
2 December 2027 for systems classified as high-risk under Annex III, and 2 August 2028 for those classified as high-risk under Annex I, as set by Regulation (EU) 2026/1744, the Digital Omnibus on AI, in force since 27 July 2026. Article 50 transparency obligations have applied since 2 August 2026, with 2 December 2026 for synthetic-content systems already on the market. Much indexed guidance still states the pre-Omnibus schedule.
Do we need a gap assessment or an attestation readiness scoping first?
Scoping when the decision is still open, the gap assessment when it is made. Attestation readiness scoping answers what SOC 2 or ISO/IEC 42001 will cost you in weeks and in money before you commit to either: $3,900, 1 week. The ISO/IEC 42001 gap assessment answers where you stand control by control against the standard: $8,900, 2 to 3 weeks.
What does a NIST AI RMF alignment review cover?
Govern, Map, Measure and Manage, scored against the systems you run rather than the ones described in your policy: $7,500, 2 weeks. The NIST AI RMF is intended for voluntary use, so it supplies a risk method rather than an obligation. Two of its subcategories, GOVERN 2.1 and MAP 5.1, are the ones this page's crosswalk cites.
Who must appoint a data protection officer?
Under GDPR, Article 37(1) requires the controller and the processor to designate a data protection officer in three listed cases, and Article 38(3) has them ensure that officer receives no instructions about how to carry out the role, which makes it an independent monitor rather than a risk owner. Under the DPDP Act 2023, section 10(2)(a) requires a Significant Data Fiduciary to appoint one, and binds nobody else. The two are different appointments with different triggers, so a single named person satisfies both only if you have written down that they do.
Is the DPDP Act 2023 in force?
Not in full. The Act was enacted in 2023 and commences in stages. G.S.R. 843(E) of 13 November 2025 brings sections 7 to 10 into force eighteen months from its publication, which falls in May 2027; the notification sets a period rather than printing a date, so the month is the honest way to state it and we do not publish a day. Section 10, the Significant Data Fiduciary duties including the Data Protection Officer and the periodic Data Protection Impact Assessment, sits inside that set.
Does the EU AI Act require a named human overseer?
For high-risk systems it requires the oversight to be assigned to people. Article 26(2) has deployers assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support, which is a higher bar than nominating whoever is on shift. Those obligations apply from 2 December 2027 for systems classified as high-risk under Annex III and 2 August 2028 for those under Annex I. Anything with legal effect belongs with counsel qualified in the relevant jurisdiction.
What does a HIPAA security risk analysis have to cover?
45 CFR 164.308(a)(1)(ii)(A) makes a risk analysis Required, not Addressable, and defines it as an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity and availability of electronic protected health information held by the covered entity or business associate. Where an AI system touches that data, prompts, retrieved context, embeddings, caches, logs and evaluation sets are all places it is held. 164.308(a)(2) separately requires an identified security official.
What does “title only” mean on your crosswalk?
That we read the clause title and not the clause text, and that we will not pretend otherwise. It applies to the two ISO/IEC 42001 cells and nowhere else: the standard is paid, its public part stops at a two-level contents list, and that list is where clause 8.2 AI risk assessment and clause 5.3 Roles, responsibilities and authorities come from. Those two cells are drawn in their own state and are never counted toward the crosswalk's read-at-provision-text line, which is why that line says five of six rather than six.
What goes in a model card, and who signs it?
The system it describes and its version, what it was trained or tuned on and what it was not, the intended use and the uses ruled out, the evaluation results with the method attached rather than a score alone, the known failure modes, and the named owner who is accountable for it. The signature is the part people skip and the part an auditor checks: a card nobody owns is documentation, not a control. Cards, a risk register with named owners and evaluation results with a method are three of the artifacts a compliance evidence request asks for.
Which of the six instruments on this page are law, and which are voluntary?
Four are law and two are voluntary. The EU AI Act, GDPR, the DPDP Act 2023 and HIPAA are binding instruments. ISO/IEC 42001:2023 is a voluntary standard, which its own Foreword establishes by pointing readers to an explanation of the voluntary nature of standards, and the NIST AI RMF is described by NIST as intended for voluntary use. Voluntary is a statement about the instrument, not about your obligations: a customer can require either one by contract, and then the contract binds you rather than the standard.
Can one risk assessment satisfy all six instruments?
No, and this page does not advise building one artifact for all six. Every one of the six names some form of risk assessment, which is what the crosswalk shows, but they ask for different contents. An Article 9(1) risk management system established, implemented, documented and maintained for high-risk AI systems, a GDPR Article 35(1) assessment of the impact of the processing on the protection of personal data, a DPDP periodic Data Protection Impact Assessment and a HIPAA risk analysis of the risks and vulnerabilities to electronic protected health information are four different documents. Evidence can be shared between them. The assessments cannot be collapsed into one.
Is the data protection officer the person who owns AI risk?
Not under GDPR. Article 38(3) has the controller and the processor ensure that the data protection officer does not receive any instructions regarding the exercise of those tasks, which makes the role an independent monitor. A risk register needs a named owner per row, and an owner is someone who can be instructed. The two are different jobs, so naming one person in both places is worth a second look before it reaches an auditor.
Does HIPAA require a named security official?
Yes. 45 CFR 164.308(a)(2) requires a covered entity or business associate to identify the security official responsible for the development and implementation of the policies and procedures required by that subpart. It is an identified person, not a committee and not a vendor. Where an AI system touches electronic protected health information, that official's remit reaches it the way it reaches any other system holding that data, including the prompts, retrieved context, embeddings, caches, logs and evaluation sets it is held in.
What does “read at provision text” mean, and why does the crosswalk say five of six?
It means we opened the instrument's own text and read the provision there, rather than reading a summary of it. Five of the six were read that way. The sixth is ISO/IEC 42001:2023, whose clause text is paid and not public: its public part stops at a two-level contents list, so clause 8.2 AI risk assessment and clause 5.3 Roles, responsibilities and authorities were read as titles and the cells say so. The figure therefore carries two counts that are never merged: six of six instruments name the artifact, and five were read at provision text.
Where can I check the sources behind your crosswalk?
On this page, under the figure. The evidence record names, per instrument, the surface the text was read at, the exact URL and how it was fetched, including the status the host returned. The method is part of the record because three of the six refuse a plain request: the EU AI Act and ISO/IEC 42001 were read in a headless browser, HIPAA through the eCFR versioner API because its web page redirects a headless browser to a bot check, and both Indian Gazette documents from their PDF streams. Every provision was read on 15 September 2026.
Our own posture, including where the answer is no, is on the security page.
Name the system your next questionnaire will ask about.
Thirty minutes with the engineer who would run the review, and a straight answer on which engagement fits.
Governance engagements $3,900 to $8,900, fixed price · Typical reply within one business day