ISO/IEC FDIS 27091/Stage 50.00/Planning date 18 Feb 2027 estimate/ISO/IEC JTC 1/SC 27
27091ISO 27091 CheckerAI privacy, read from the rules that apply today
A.6.2.2
ISO/IEC 42001:2023
A.6 AI system life cycle

Control A.6.2.2: AI system requirements and specification

Control in force todayISO/IEC 42001:2023, Annex APrivacy overlay: The lifecycle and where privacy risk entersPublic scope

Write down the requirements for any new AI system and for any material enhancement of an existing one.

What control A.6.2.2 asks

Write down the requirements for any new AI system and for any material enhancement of an existing one.

Why it matters for privacy

A requirement that does not mention personal data will not be tested for it. The specification is the last cheap place to stop a privacy problem.

The 27091 overlay

Where the draft lands: requirements carry the risk. The abstract applies to systems being developed. The specification is where the organization decides what the system will do with personal data.

Basis for A.6.2.2: the ISO page 56582 and the ISO/IEC 42001:2023 control record. No draft requirement is stated here: the abstract gives the direction and the text is not public. The lifecycle and where privacy risk enters.

Evidence for control A.6.2.2

The list below is what a reviewer will want produced, not described. For control A.6.2.2 the list is written for an AI system that touches personal data, so a system with no personal data will need a subset.

  • Requirements Requirements specification spanning the life cycle
  • Requirements Documented rationale and goals (business case, customer request, policy)
  • Requirements Records of requirements revisited when the system cannot operate as intended

Where control A.6.2.2 commonly fails

  • Rationale for building the system undocumented
  • Requirements never revisited after feasibility changes

What to do about control A.6.2.2 before the draft lands

Add privacy requirements to each specification: the data allowed, the purpose, the retention, the output restrictions, the logging and the tests that prove them.

Do not rebuild around a draft. Control A.6.2.2 already requires the evidence above, and the privacy preparation is the same control applied to the personal data an AI system touches.

Read across from control A.6.2.2

← Control A.6.1.3 | Control A.6.2.3 →

Open the full index. The public record behind control A.6.2.2 shows the scope and the lifecycle.

Source for control A.6.2.2: ISO/IEC 42001:2023, Annex A, retrieved 22 October 2026, at the standards library. The overlay rests on the public 27091 record. Every source.