AI Governance
AI governance has become a procurement requirement. Enterprise customers ask vendors for an AI use policy, a model inventory and a risk register, and auditors are adding AI controls to SOC 2. We help you define the protocol, set up the controls and audit the result before the questionnaire arrives.
Not long ago, AI governance was a policy page and a committee. Today it gets checked: security questionnaires carry an AI section, SOC 2 auditors ask how models are monitored, and NIST AI RMF and ISO 42001 give customers a checklist. Governance has moved from something you state to something you prove.
We start with the footprint: every model you run, including the AI inside your vendors' tools. From it we help you define the governance protocol, set up the logging, monitoring and circuit breakers that enforce it, and audit the result against the frameworks your customers name. The protocol, the controls and the evidence stay with you.
Where Responsible AI Meets Returns
Responsible AI is AI that is fair, safe, reliable and private, with someone accountable for it. Governance is what makes that real: named owners, recorded decisions, tested controls. Companies that scale AI with governance report higher returns than those that scale without it.
- 3× ROI reported by companies scaling AI alongside governance, against about 2× for those scaling AI alone. BCG Applied AI Index, 1,330 leaders, 2026
- 30% higher AI-attributable operating profit in the top quartile of AI-ethics spend than in the bottom quartile. IBM and Notre Dame, 915 executives, 2025
- 53% of executives say their own AI-ethics governing body is ineffective. A committee on its own is not governance. IBM and Notre Dame, same survey, 2025
How We Work
Governance that passes review is built, not written. We find what AI is running, set the rules, put the controls into your systems and audit the result. The policy, model inventory and risk register come out of that work.
Find what is actually running
Every AI system in use: the models your team built, the AI inside your vendors' tools, the assistants your people adopted on their own. What goes in, what comes out, who relies on it, who approved it.
Set the rules and build the controls
Which uses are allowed, which data may reach which model, who approves a new vendor, what the AI may do without a person in the loop. Enforced in the systems, not a handbook: every model call logged through one gateway, monitoring on what the models produce, circuit breakers on automated actions, cost ceilings, role-based access.
Audit the result and keep it current
Controls tested against NIST AI RMF, ISO 42001, your SOC 2 and the questionnaires your customers actually send. A fix list in priority order. The policy, model inventory and risk register written from what is running, and kept accurate by the controls behind them.
Who Needs It
Governance requirements arrive with the first enterprise customer, the first SOC 2 report or the first model that touches regulated data, not with headcount. We have done this work for a single founder and for Inc. 500 companies, including clients in healthcare, finance and defense contracting.
- Enterprise customers
- The AI section of the security questionnaire goes to every vendor, whatever its size. The deal waits until the answers come back.
- SOC 2 auditors
- Once you hold a report, AI falls under the controls you already attest to: access, change management, vendor review and monitoring.
- NIST AI RMF and ISO 42001
- Named in RFPs as the framework a vendor should follow or the certificate it should hold. Neither has a headcount threshold.
- State AI laws
- There is no single federal AI law. Colorado and Texas have passed their own and more states are drafting. They apply by what the system does, not by company size.
- Sector rules
- HIPAA when AI touches patient data. The FTC already treats misleading AI claims as deceptive practice. Neither waits for a new AI law.
- EU AI Act
- If you sell into Europe, it adds its own obligations, phased in by use case.
It Doesn't End With a Policy
Controls drift. A model gets swapped, a vendor changes its terms, a team turns off a monitor that was in the way, a new AI tool arrives through a credit card. Most of our clients keep us on after the first engagement for periodic spot checks and the occasional full audit, so a dropped control or a quiet drift is caught by us, not by the next questionnaire.
Where an audit calls for changes, our AI transformation practice builds them, with the same people who found them.
Questions We Get Asked
If the AI belongs to a vendor, is it still our problem?
Yes. Most of the AI a company runs is someone else's model inside someone else's tool: the support platform that drafts replies, the CRM that scores leads, the coding assistant, the note-taker on every sales call. Each one sends some of your data, and your customers' data, to a model you didn't choose, and your customers hold you responsible for it all the same. That's why questionnaires ask for subprocessors and training-data commitments, and why a policy alone can't answer them. The model inventory has to cover vendor AI, and each AI vendor needs an assessment: what it sends, where it goes, whether it trains on it, and who signed off.
Can't our team do this ourselves?
Probably, and it probably shouldn't. The people who built a system know what it is meant to do, and they stop looking there. An outside reviewer asks the questions nobody inside thinks to ask: who approved this vendor, what happens when this model is wrong, would anyone notice. Those are the questions your customer's security team will ask, so it pays to hear them from us first. What your team keeps is the inventory, the controls and the evidence, so the next questionnaire is theirs to answer.
Can't we just have an AI draft the policy?
You can, and it will read fine. What a security reviewer tests is whether it is true: whether you know what AI is running, whether the controls it describes exist, and whether someone checks. A policy that says model output is monitored, when nothing monitors it, fails the review and costs more credibility than no policy at all. The documents are the last step of the work, not the work.
We already use a governance platform like Credo AI. Why would we need you?
Keep it. A platform like Credo AI, Holistic AI or a compliance tool like Vanta is a system of record: it holds the inventory, maps policy packs to NIST AI RMF, ISO 42001 and SOC 2, and collects evidence. It governs what someone registered in it. We do the parts around it. We find the AI the platform's integrations don't see, the models inside your vendors' tools and the assistants your people signed up for on their own, and get them into the inventory. We decide with you which requirements in a policy pack actually apply, who owns each one, and what "monitored" means for your systems, then build the gateway logging, monitors and circuit breakers that produce the evidence the platform is waiting for. And when the dashboard shows every control green, we spot-check whether that is still true. If you don't have a platform yet, we help you choose one, or tell you that at your size a well-kept register is enough.
How do we choose a vendor for AI governance?
Ask what you will have at the end. A good AI governance partner leaves you with documents your customers and auditor will accept, controls running in your systems that back those documents up, and a named owner for the work. Ask who writes the model inventory, whether they can change code or only recommend changes, whether they cover the AI inside your vendors' products, and how you exit if the first phase isn't working.
What should we prioritize when selecting an AI governance partner?
Evidence over policy. A policy nobody can show is followed doesn't survive a security review. Prioritize a partner who builds the logging, monitoring and ownership behind each document, who works from the US frameworks your customers name (NIST AI RMF, ISO 42001, SOC 2), and who covers third-party AI, because most of the AI a company runs is someone else's model inside someone else's tool.
What proof of AI governance do enterprise customers ask vendors for?
Usually three things: an AI use policy, an inventory of the models and AI vendors you use (including subprocessors), and a risk register with owners. Behind those come the follow-up questions: whether customer data is used to train models, how you monitor model output over time, what happens when the AI does something unexpected, and who owns AI risk. Each question should point at a document and at a control that's actually running.
Do we need ISO 42001, or is NIST AI RMF enough?
It depends on what your customers ask for. NIST AI RMF is a voluntary US framework: it's the common reference for how to structure AI risk work, but there's no certificate. ISO/IEC 42001 is a management-system standard you can be certified against by an accredited certification body. If a customer or RFP asks for a certificate, that means ISO 42001. Either way, the same inventory, risk register and controls do most of the work, so we build them once and map them to both.
Can you fill in our customer's AI security questionnaire?
On request, yes, as a separately scoped piece of work. The standard engagement leaves you with a question-to-artifact map and the evidence behind each answer, so your team can fill in most questionnaires without us. When a specific customer's questionnaire needs more, we draft the answers with you from the artifacts and attach the evidence. You review and sign them, because the answers are your company's commitments. Where an honest answer today would be "we don't do that yet", we say so, and either build the control or help you word a plan the customer will accept.
How is this different from a SOC 2 audit?
A SOC 2 report is an attestation from an independent CPA firm, tested against the AICPA Trust Services Criteria. We don't issue SOC 2 reports. We build the AI-specific controls and the evidence your auditor will test, so AI doesn't become the exception in your next report. SOC 2 also doesn't answer most AI questionnaire questions on its own, which is why customers send them separately.
Who does the work?
Senior practitioners who build AI systems in production and have run security and compliance programs. The people who define your protocol are the ones who set up the controls and sit in the questionnaire review with you. There is no handoff to a junior team.
How does an engagement start?
With a free 30-minute call about what your customers and auditors are asking for, and what AI you're running. After the call you get a written read: where you stand, which questions you can already answer, and which need work. If it makes sense to go further, we propose a scoped first phase with a clean exit if it isn't working. It can run as a project on its own, or as part of a fractional CTO and CAIO engagement.
Further Reading
The three-part series behind the method, written from a real engagement.
Find Out Where You Stand
Bring the questionnaire, or just the question that's holding up the deal. The first conversation is free, and you leave with a written read of what it will take to answer it.