ISO/IEC FDIS 27091: what is known, and what is not
ISO/IEC FDIS 27091 is the first edition of the privacy protection guidance for AI systems. It is in the approval phase: stage 50.00 was recorded on 13 July 2026 and the FDIS ballot and publication follow. It is not published, it cannot be certified against, its text is not public, and its clause structure is not stated on any page here. This page separates what the record proves from what a summary reports and what is our estimate.
| Field | Public record | Source |
|---|---|---|
| Designation | ISO/IEC FDIS 27091, Edition Edition 1, 35 pages | ISO page 56582 |
| Title | Cybersecurity and Privacy, Artificial Intelligence, Privacy protection | ISO page |
| Committee | ISO/IEC JTC 1/SC 27, information security, cybersecurity and privacy protection | ISO page; stage feed |
| ICS | 35.030 and 35.240.01 | ISO page |
| Stage | 50.00, Final text received or FDIS registered for formal approval, 13 July 2026 | ISO page; stage feed |
| DIS ballot | Opened 3 December 2025, closed 26 February 2026; approved for registration as FDIS 8 July 2026 | ISO page |
| Project start | 10.99 New project approved, 3 February 2023 | ISO page |
| Predecessor | None. This is the first edition of ISO/IEC 27091. | ISO page |
| Publication | No ISO publication date recorded. Publication expected in 2027. The planning date is an estimate. | ISO page |
| Text | Not public. The ISO page publishes the abstract, the general information and the stage record; the draft text is not published there. | ISO page |
| Certification | None. The draft is guidance, not a certifiable management system standard. A certificate is issued against ISO/IEC 42001:2023 or ISO/IEC 27701. | ISO page; ISO/IEC 42001:2023 |
The ISO page records stage 50.00 and the earlier dates. Stages 50.20, 50.60, 60.00 and 60.60 are listed without a date. The site does not infer an outcome or a date.
What the draft says it is for
Read plainly, the abstract says the document sets out how an organization should deal with privacy risk in AI systems and in machine-learning models. It asks for that risk to be found across the life of the system, for the consequences to be judged, and for a decision on how to treat them. It reaches organizations of every size and kind, naming private firms, public bodies, government and not-for-profit organizations among those that build AI systems or use them. The ISO wording is not reproduced on this site.
That is the whole of the public description. It names a subject (privacy risk), a path (identify, evaluate, treat) and a population (any organization that develops or uses AI systems). It does not publish a control, a technique, a defined term or a clause.
The six areas the abstract points at
| Area | Page | Basis | Controls |
|---|---|---|---|
| S1 | Scope, role and who answers | Public scope | 5 controls |
| S2 | The lifecycle and where privacy risk enters | Public scope | 8 controls |
| S3 | Evaluating the consequences | Public scope | 4 controls |
| S4 | Treating the risk: data and third parties | Reading | 7 controls |
| S5 | Operating, monitoring and telling people | Reading | 10 controls |
| S6 | Evidence, review and the date | Public scope | 4 controls |
27091 is not a revision of ISO/IEC 42001
Buyers ask whether the draft replaces the AI management system standard. It does not. ISO/IEC 42001:2023 is the standard a certificate is issued against; 27091 is privacy guidance in its first edition. The two do different jobs, and the control pages read the one that applies today.
| Question | ISO/IEC FDIS 27091 | ISO/IEC 42001:2023 |
|---|---|---|
| What it is | Privacy protection guidance, first edition | AI management system requirements |
| Stage | 50.00, 13 July 2026 | Published, December 2023 |
| Certifiable | No. Guidance only | Yes, a certificate can be issued |
| Creates a transition | No | No. The edition is current |
| What it changes | How privacy risk is found and treated in AI | The management system an auditor tests |
The stage record and the planning date
| Stage | What it means | Date |
|---|---|---|
| 10.99 | New project approved | 3 February 2023 |
| 20.00 | New project registered in TC/SC work programme | 3 February 2023 |
| 30.00 | Committee draft registered | 8 April 2025 |
| 30.99 | CD approved for registration as DIS | 1 October 2025 |
| 40.00 | DIS registered | 2 October 2025 |
| 40.20 | DIS ballot initiated, 12 weeks | 3 December 2025 |
| 40.60 | Close of voting | 26 February 2026 |
| 40.99 | Full report circulated, DIS approved for registration as FDIS | 8 July 2026 |
| 50.00 | Final text received or FDIS registered for formal approval | 13 July 2026 |
| 50.20 | Proof sent to secretariat or FDIS ballot initiated, 8 weeks | Not recorded |
| 50.60 | Close of voting, proof returned by secretariat | Not recorded |
| 60.00 | International Standard under publication | Not recorded |
| 60.60 | International Standard published | Not recorded |
Stage dates to 50.00 are from the ISO page. Later dates are blank because ISO has not recorded them. Publication is expected in 2027. The planning date of 18 February 2027 is an estimate, labelled wherever it appears.
The rules this is built from
Read from the real rules, not invented. The 38 control pages are the ISO/IEC 42001:2023 Annex A controls, read from the standards library: 101 evidence lines and 80 common failure lines, each cited to its control. The privacy layer is read from the public ISO/IEC FDIS 27091 record, the ISO abstract and the stage feed. The draft text is not public and is not reproduced.
ISO/IEC 42001:2023, Annex A
Each page states the control in our words, the evidence an auditor asks for, the common gaps and the privacy work the draft points at.
Open the control indexWhat the draft covers
Scope and role, the lifecycle, the evaluation of consequences, treatment, operation and evidence.
Read the public recordThe role and the four markets
Controller or processor, the lifecycle stages, and the instruments named for the US, EU, UK and Australia.
Open the referenceThe ISO/IEC FDIS 27091 text is not public and is not reproduced. The ISO/IEC 42001:2023 text is not reproduced either. Every source.