AI Accuracy, Robustness & Security Standard
Ensure AI systems achieve appropriate levels of accuracy, robustness, and cybersecurity.
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AI Accuracy, Robustness and Security Standard
Document Type: Standard
Standard ID: STD-AI-008
Standard Title: AI Accuracy, Robustness and Security Standard
Version: 1.0
Effective Date: 2025-08-01
Next Review Date: 2026-08-01
Review Frequency: Annually or upon regulatory change
Parent Policy: POL-AI-001 - Artificial Intelligence Policy
Owner: Chief Technology Officer
Approved By: AI Governance Committee Chair
Status: Draft
Classification: Internal Use Only
TABLE OF CONTENTS
- Document History
- Objective
- Scope and Applicability
- Control Standard
- Supporting Procedures
- Compliance
- Roles and Responsibilities
- Exceptions
- Enforcement
- Key Performance Indicators (KPIs)
- Training Requirements
- Definitions
- Link with AI Act and ISO42001
DOCUMENT HISTORY
| Version | Date | Author | Changes | Approval Date | Approved By |
|---|---|---|---|---|---|
| 0.1 | 2025-07-05 | David Lee, Chief Technology Officer | Initial draft | - | - |
| 0.2 | 2025-07-20 | David Lee, Chief Technology Officer | Added security details | - | - |
| 0.3 | 2025-08-01 | David Lee, Chief Technology Officer | Incorporated security feedback | - | - |
| 1.0 | 2025-08-01 | David Lee, Chief Technology Officer | Final version approved - GRC restructured | 2025-07-25 | Jane Doe, AI Governance Committee Chair |
OBJECTIVE
This standard defines requirements for ensuring AI systems achieve appropriate levels of accuracy, robustness, and cybersecurity in compliance with EU AI Act Article 15.
Primary Goals:
- Ensure AI systems achieve appropriate accuracy levels per Article 15(1)
- Ensure AI systems are robust per Article 15(4)
- Ensure AI systems are resilient against cybersecurity threats per Article 15(5)
SCOPE AND APPLICABILITY
2.1 Mandatory Applicability
This standard is mandatory for:
- All high-risk AI systems (EU AI Act Article 15)
- All AI systems with significant impact on health, safety, or fundamental rights
2.2 Recommended Applicability
This standard is recommended for:
- All AI systems for best practices
- Limited-risk and minimal-risk AI systems (voluntary)
2.3 Requirements Covered
- Accuracy requirements, testing, and monitoring
- Robustness requirements, testing, and drift detection
- Cybersecurity requirements, threat assessment, and security testing
2.4 Out of Scope
- General software quality (covered by software development standards)
- Non-AI system security (covered by IT security standards)
- Requirements outside EU AI Act scope
CONTROL STANDARD
Control ARS-001: Accuracy Requirements Definition
Control ID: ARS-001
Control Name: Accuracy Requirements and Metrics Definition
Control Type: Preventive
Control Frequency: Per high-risk AI system, during design phase
Risk Level: High
Control Objective
Define accuracy requirements based on intended purpose per Article 15(1) to ensure AI systems achieve appropriate accuracy levels for their use case, enabling safe and effective deployment.
Control Requirements
CR-001.1: Accuracy Requirements Documentation
Define and document accuracy requirements with appropriate metrics and thresholds.
Accuracy Metrics:
| Metric | Definition | Use Case | Target (High-Risk) |
|---|---|---|---|
| Overall Accuracy | % of correct predictions | General classification | ≥95% |
| Precision | % of positive predictions that are correct | When false positives costly | ≥95% |
| Recall | % of actual positives correctly identified | When false negatives costly | ≥95% |
| F1 Score | Harmonic mean of precision and recall | Balanced metric | ≥95% |
| ROC-AUC | Area under ROC curve | Binary classification | ≥0.95 |
| Domain-Specific | Custom metrics for specific domain | Domain-specific use cases | Defined per use case |
Mandatory Actions:
- Define accuracy requirements based on intended purpose
- Select appropriate metrics
- Set accuracy thresholds
- Document requirements
- Obtain AI System Owner approval
- Review and update annually
Accuracy Requirements by Use Case:
| Use Case | Accuracy Metric | Threshold | Justification |
|---|---|---|---|
| Medical Diagnosis | Precision, Recall | ≥98% | High safety impact |
| Credit Scoring | ROC-AUC, Precision | ≥0.95, ≥95% | Financial impact |
| Fraud Detection | Precision, Recall | ≥95%, ≥90% | Balance false positives/negatives |
| Image Classification | Overall Accuracy | ≥95% | General use case |
Evidence Required:
- Accuracy Requirements Document (DOC-AI-ARS-001)
- Metrics definitions
- Threshold specifications
- Approval records
- Annual review records
Audit Verification:
- Verify accuracy requirements defined for all high-risk AI
- Confirm metrics appropriate for use case
- Check thresholds set and justified
- Validate approval obtained
- Verify annual review completed
Control ARS-002: Accuracy Testing
Control ID: ARS-002
Control Name: Accuracy Testing and Validation
Control Type: Preventive
Control Frequency: Before deployment, after model updates
Risk Level: High
Control Objective
Test AI system accuracy before deployment to verify it meets defined accuracy requirements, ensuring safe and effective operation.
Control Requirements
CR-002.1: Comprehensive Accuracy Testing
Conduct comprehensive accuracy testing using representative test data.
Testing Requirements:
| Requirement | Specification | Implementation |
|---|---|---|
| Test Data | Representative of production data | Test dataset validation |
| Use Case Coverage | Test across all use cases | Use case test matrix |
| User Group Coverage | Test for all user groups | User group test matrix |
| Metric Calculation | Calculate all defined metrics | Automated metric calculation |
| Threshold Verification | Verify all thresholds met | Threshold compliance check |
| Documentation | Document all test results | Test report |
Mandatory Actions:
- Plan accuracy testing
- Prepare representative test data
- Execute tests across all use cases
- Test for all user groups
- Calculate all defined metrics
- Verify threshold compliance
- Document test results
- Block deployment if thresholds not met
Accuracy Test Plan:
| Test Component | Description | Success Criteria |
|---|---|---|
| Overall Accuracy Test | Test overall accuracy | Meets threshold |
| Precision Test | Test precision | Meets threshold |
| Recall Test | Test recall | Meets threshold |
| Use Case Tests | Test each use case | All use cases meet thresholds |
| User Group Tests | Test each user group | All groups meet thresholds |
| Edge Case Tests | Test edge cases | Acceptable performance |
Evidence Required:
- Accuracy Test Plan (PLAN-AI-ARS-001)
- Test results (TEST-AI-ARS-001)
- Analysis reports
- Threshold compliance verification
- Approval records
Audit Verification:
- Verify accuracy testing conducted before deployment
- Confirm representative test data used
- Check all use cases tested
- Validate all user groups tested
- Verify thresholds met
- Check deployment blocked if thresholds not met
Control ARS-003: Accuracy Monitoring
Control ID: ARS-003
Control Name: Production Accuracy Monitoring
Control Type: Detective
Control Frequency: Continuous
Risk Level: Medium
Control Objective
Monitor accuracy in production to detect accuracy degradation, identify issues early, and enable timely corrective actions to maintain AI system performance.
Control Requirements
CR-003.1: Continuous Accuracy Monitoring
Implement continuous accuracy monitoring with alerting and analysis.
Monitoring Requirements:
| Requirement | Specification | Implementation |
|---|---|---|
| Real-Time Monitoring | Monitor accuracy metrics in real-time | Real-time monitoring system |
| Threshold Alerting | Alert when accuracy drops below threshold | Automated alerting |
| Trend Analysis | Analyze accuracy trends | Trend analysis tools |
| Issue Investigation | Investigate accuracy issues promptly | Investigation procedures |
| Corrective Actions | Implement corrective actions | Corrective action procedures |
Mandatory Actions:
- Implement accuracy monitoring
- Set up alerting for threshold breaches
- Monitor continuously
- Track accuracy trends
- Investigate accuracy issues
- Implement corrective actions
- Document monitoring results
Accuracy Monitoring Metrics:
| Metric | Threshold | Alert Level | Frequency |
|---|---|---|---|
| Overall Accuracy | < 95% (high-risk) | Warning | Daily |
| Precision | < 95% | Warning | Daily |
| Recall | < 95% | Warning | Daily |
| Accuracy Degradation | > 2% drop | Critical | Real-time |
| Accuracy Stability | > 2% variation | Warning | Weekly |
Evidence Required:
- Accuracy monitoring dashboard
- Alert logs
- Trend analysis reports
- Investigation records
- Corrective action records
- Monthly accuracy reports
Audit Verification:
- Verify accuracy monitoring implemented
- Confirm alerting configured
- Check monitoring reviewed regularly
- Validate issues investigated
- Verify corrective actions implemented
Control ARS-004: Robustness Requirements
Control ID: ARS-004
Control Name: Robustness Requirements Definition
Control Type: Preventive
Control Frequency: Per high-risk AI system, during design phase
Risk Level: High
Control Objective
Define robustness requirements per Article 15(4) to ensure AI systems are resilient to errors, faults, inconsistencies, and adversarial conditions, maintaining performance across diverse scenarios.
Control Requirements
CR-004.1: Comprehensive Robustness Requirements
Define robustness requirements across all relevant dimensions.
Robustness Dimensions:
| Dimension | Description | Requirements | Metrics |
|---|---|---|---|
| Technical Robustness | Resilience to errors, faults, inconsistencies | Error handling, fault tolerance | Error rate, fault recovery time |
| Input Robustness | Handling of edge cases, outliers, adversarial inputs | Input validation, outlier handling | Edge case success rate, adversarial robustness |
| Environmental Robustness | Performance across different conditions | Environmental adaptation | Performance across conditions |
| Temporal Robustness | Stability over time (no drift) | Drift detection, model stability | Drift score, performance stability |
Mandatory Actions:
- Define robustness requirements
- Establish robustness metrics
- Set robustness thresholds
- Document requirements
- Obtain approval
- Review and update annually
Robustness Requirements by Dimension:
| Dimension | Metric | Threshold | Justification |
|---|---|---|---|
| Technical Robustness | Error rate | < 1% | Acceptable error handling |
| Input Robustness | Edge case success rate | ≥90% | Handle edge cases |
| Adversarial Robustness | Adversarial success rate | ≥85% | Resist adversarial attacks |
| Environmental Robustness | Performance variation | < 5% | Consistent across conditions |
| Temporal Robustness | Drift score | < 0.1 | Stable over time |
Evidence Required:
- Robustness Requirements Document (DOC-AI-ARS-002)
- Metrics and thresholds
- Approval records
- Annual review records
Audit Verification:
- Verify robustness requirements defined
- Confirm all dimensions covered
- Check thresholds set
- Validate approval obtained
Control ARS-005: Robustness Testing
Control ID: ARS-005
Control Name: Robustness Testing and Validation
Control Type: Preventive
Control Frequency: Before deployment, after model updates
Risk Level: High
Control Objective
Test AI system robustness to verify it meets defined robustness requirements, ensuring resilience to errors, faults, and adversarial conditions.
Control Requirements
CR-005.1: Comprehensive Robustness Testing
Conduct comprehensive robustness testing across all dimensions.
Test Types:
| Test Type | Purpose | Test Method | Success Criteria |
|---|---|---|---|
| Edge Case Testing | Test handling of edge cases | Edge case test suite | ≥90% success rate |
| Stress Testing | Test under extreme conditions | Stress test scenarios | System remains functional |
| Adversarial Testing | Test resistance to adversarial attacks | Adversarial attack simulations | ≥85% success rate |
| Fault Injection Testing | Test fault tolerance | Fault injection scenarios | System recovers gracefully |
| Environmental Variation Testing | Test across different conditions | Environmental test matrix | < 5% performance variation |
| Drift Testing | Test temporal stability | Drift simulation | Drift score < 0.1 |
Mandatory Actions:
- Plan robustness testing
- Execute all test types
- Analyze results
- Verify compliance with requirements
- Document results
- Block deployment if requirements not met
Robustness Test Plan:
| Test Component | Description | Success Criteria |
|---|---|---|
| Edge Case Tests | Test edge case handling | ≥90% success rate |
| Stress Tests | Test under stress | System functional |
| Adversarial Tests | Test adversarial resistance | ≥85% success rate |
| Fault Injection Tests | Test fault tolerance | Graceful recovery |
| Environmental Tests | Test across conditions | < 5% variation |
| Drift Tests | Test temporal stability | Drift score < 0.1 |
Evidence Required:
- Robustness Test Plan (PLAN-AI-ARS-002)
- Test results (TEST-AI-ARS-002)
- Analysis reports
- Compliance verification
- Approval records
Audit Verification:
- Verify robustness testing conducted
- Confirm all test types executed
- Check results meet requirements
- Validate deployment blocked if requirements not met
Control ARS-006: Model Drift Detection
Control ID: ARS-006
Control Name: Model Drift Detection and Response
Control Type: Detective
Control Frequency: Continuous
Risk Level: Medium
Control Objective
Monitor for data drift and concept drift to detect performance degradation early and enable timely model updates or retraining to maintain AI system performance.
Control Requirements
CR-006.1: Drift Detection Implementation
Implement comprehensive drift detection with alerting and response procedures.
Drift Types:
| Drift Type | Description | Detection Method | Threshold |
|---|---|---|---|
| Data Drift | Change in input data distribution | Statistical distribution comparison | > 0.1 |
| Concept Drift | Change in relationship between inputs and outputs | Performance monitoring | > 5% performance drop |
| Label Drift | Change in output distribution | Output distribution comparison | > 0.1 |
Mandatory Actions:
- Implement drift detection
- Monitor continuously
- Alert on drift detection
- Investigate drift causes
- Retrain or update model if needed
- Document drift events and responses
Drift Detection Configuration:
| Detection Method | Metric | Threshold | Alert Level |
|---|---|---|---|
| Statistical Distance | KL divergence, Wasserstein distance | > 0.1 | Warning |
| Performance Monitoring | Accuracy, precision, recall | > 5% drop | Critical |
| Distribution Comparison | Distribution similarity | < 0.9 | Warning |
Evidence Required:
- Drift detection configuration
- Drift monitoring dashboard
- Alert logs
- Drift investigation records
- Retraining records
- Monthly drift reports
Audit Verification:
- Verify drift detection implemented
- Confirm monitoring continuous
- Check alerts configured
- Validate drift investigated
- Verify model retrained when needed
Control ARS-007: Cybersecurity Requirements
Control ID: ARS-007
Control Name: Cybersecurity Requirements and Threat Assessment
Control Type: Preventive
Control Frequency: Per high-risk AI system, during design phase
Risk Level: High
Control Objective
Define cybersecurity requirements and assess AI-specific security threats per Article 15(5) to ensure AI systems are resilient against cybersecurity threats and protect against AI-specific attack vectors.
Control Requirements
CR-007.1: Security Requirements and Threat Assessment
Define security requirements and assess AI-specific threats.
Security Dimensions:
| Dimension | Requirement | Implementation | Verification |
|---|---|---|---|
| Confidentiality | Protect sensitive data and models | Encryption, access controls | Security testing |
| Integrity | Prevent unauthorized modifications | Integrity checks, access controls | Security testing |
| Availability | Ensure system availability | Redundancy, DDoS protection | Availability testing |
| Authentication | Verify user identities | Authentication mechanisms | Security testing |
| Authorization | Control access appropriately | Role-based access control | Security testing |
AI-Specific Security Threats:
| Threat Type | Description | Defense Strategy | Testing Method |
|---|---|---|---|
| Adversarial Attacks | Malicious inputs to fool model | Adversarial training, input validation | Adversarial testing |
| Model Extraction | Stealing model through queries | Rate limiting, query monitoring | Model extraction testing |
| Data Poisoning | Corrupting training data | Data validation, provenance tracking | Data quality checks |
| Model Inversion | Extracting training data from model | Differential privacy, access controls | Model inversion testing |
| Backdoor Attacks | Hidden malicious behavior | Model verification, testing | Backdoor detection testing |
Mandatory Actions:
- Define security requirements
- Conduct threat modeling
- Assess AI-specific threats
- Implement security controls
- Test security controls
- Document security architecture
Evidence Required:
- Security Requirements Document (DOC-AI-ARS-003)
- Threat model
- AI threat assessment
- Security control documentation
- Test results
Audit Verification:
- Verify security requirements defined
- Confirm threat modeling conducted
- Check AI-specific threats assessed
- Validate security controls implemented
- Verify security testing completed
Control ARS-008: Security Testing
Control ID: ARS-008
Control Name: Cybersecurity Testing and Validation
Control Type: Preventive
Control Frequency: Before deployment, annually, after security updates
Risk Level: High
Control Objective
Test AI system security to verify it meets security requirements and is resilient against cybersecurity threats, including AI-specific attack vectors.
Control Requirements
CR-008.1: Comprehensive Security Testing
Conduct comprehensive security testing including AI-specific tests.
Test Types:
| Test Type | Purpose | Test Method | Success Criteria |
|---|---|---|---|
| Penetration Testing | Test system security | Penetration test | No critical vulnerabilities |
| Vulnerability Scanning | Identify vulnerabilities | Automated scanning | No critical vulnerabilities |
| Adversarial Robustness Testing | Test resistance to adversarial attacks | Adversarial attack simulations | ≥85% success rate |
| Security Code Review | Review code for security issues | Manual and automated review | No critical issues |
| Dependency Scanning | Identify vulnerable dependencies | Dependency scanning tools | No critical vulnerabilities |
| Model Extraction Testing | Test resistance to model extraction | Model extraction attempts | Model protected |
| Data Poisoning Testing | Test resistance to data poisoning | Data poisoning simulations | System detects poisoning |
Mandatory Actions:
- Plan security testing
- Execute all test types
- Remediate findings
- Verify remediation
- Document results
- Block deployment if critical vulnerabilities found
Security Test Plan:
| Test Component | Description | Success Criteria |
|---|---|---|
| Penetration Tests | Test system security | No critical vulnerabilities |
| Vulnerability Scans | Scan for vulnerabilities | No critical vulnerabilities |
| Adversarial Tests | Test adversarial resistance | ≥85% success rate |
| Code Review | Review code security | No critical issues |
| Dependency Scans | Scan dependencies | No critical vulnerabilities |
| AI-Specific Tests | Test AI-specific threats | Threats mitigated |
Evidence Required:
- Security Test Plan (PLAN-AI-ARS-003)
- Test results (TEST-AI-ARS-003)
- Remediation records
- Verification results
- Approval records
Audit Verification:
- Verify security testing conducted
- Confirm all test types executed
- Check critical vulnerabilities remediated
- Validate deployment blocked if critical vulnerabilities found
SUPPORTING PROCEDURES
This standard is implemented through the following detailed procedures:
Procedure PROC-AI-ARS-001: Accuracy Testing Procedure
Purpose: Define step-by-step process for accuracy testing
Owner: Chief Technology Officer
Implements: Controls ARS-001, ARS-002
Procedure Steps:
- Define accuracy requirements - Control ARS-001
- Prepare test data
- Plan accuracy testing
- Execute accuracy tests - Control ARS-002
- Analyze results
- Verify threshold compliance
- Document results
- Obtain approval
Outputs:
- Accuracy Requirements Document
- Accuracy Test Plan
- Test results
- Approval records
Procedure PROC-AI-ARS-002: Robustness Testing Procedure
Purpose: Define process for robustness testing
Owner: Chief Technology Officer
Implements: Controls ARS-004, ARS-005, ARS-006
Procedure Steps:
- Define robustness requirements - Control ARS-004
- Plan robustness testing
- Execute robustness tests - Control ARS-005
- Implement drift detection - Control ARS-006
- Analyze results
- Verify compliance
- Document results
Outputs:
- Robustness Requirements Document
- Robustness Test Plan
- Test results
- Drift detection configuration
Procedure PROC-AI-ARS-003: Cybersecurity Assessment Procedure
Purpose: Define process for cybersecurity assessment
Owner: Chief Technology Officer
Implements: Controls ARS-007, ARS-008
Procedure Steps:
- Define security requirements - Control ARS-007
- Conduct threat modeling
- Assess AI-specific threats
- Plan security testing
- Execute security tests - Control ARS-008
- Remediate findings
- Verify remediation
- Document results
Outputs:
- Security Requirements Document
- Threat model
- Security Test Plan
- Test results
- Remediation records
Procedure PROC-AI-ARS-004: Performance Monitoring Procedure
Purpose: Define process for continuous performance monitoring
Owner: Chief Technology Officer
Implements: Controls ARS-003, ARS-006
Procedure Steps:
- Configure accuracy monitoring - Control ARS-003
- Configure drift detection - Control ARS-006
- Set up alerting
- Monitor continuously
- Investigate issues
- Implement corrective actions
- Report metrics
Outputs:
- Monitoring configuration
- Alert logs
- Investigation records
- Corrective action records
- Performance reports
COMPLIANCE
5.1 Compliance Monitoring
Monitoring Approach: Continuous automated monitoring supplemented by monthly manual reviews and quarterly comprehensive audits.
Compliance Metrics:
| Metric | Target | Measurement Method | Frequency | Owner |
|---|---|---|---|---|
| Accuracy Requirements Coverage | 100% | % of high-risk AI with accuracy requirements | Monthly | Chief Technology Officer |
| Accuracy Threshold Compliance | 100% | % of AI systems meeting accuracy thresholds | Daily | Chief Technology Officer |
| Robustness Requirements Coverage | 100% | % of high-risk AI with robustness requirements | Monthly | Chief Technology Officer |
| Robustness Threshold Compliance | 100% | % of AI systems meeting robustness thresholds | Monthly | Chief Technology Officer |
| Security Requirements Coverage | 100% | % of high-risk AI with security requirements | Monthly | IT Security Manager |
| Security Vulnerability Count | 0 critical | Number of critical vulnerabilities | Monthly | IT Security Manager |
| Drift Detection Coverage | 100% | % of AI systems with drift detection | Monthly | Chief Technology Officer |
| Security Testing Completion | 100% | % of required security tests completed | Quarterly | IT Security Manager |
Monitoring Tools:
- Performance Monitoring Dashboard
- Security Monitoring Dashboard
- Compliance Reports
- Monthly compliance reports
- Quarterly AI Governance Committee reviews
5.2 Internal Audit Requirements
Audit Frequency: Annually (minimum)
Audit Scope:
- Accuracy requirements completeness
- Accuracy testing quality
- Robustness requirements completeness
- Robustness testing quality
- Security requirements completeness
- Security testing quality
- Drift detection effectiveness
- Controls effectiveness (ARS-001 through ARS-008)
Audit Activities:
- Review 100% of high-risk AI for requirements
- Sample 20% of tests for quality review
- Test accuracy monitoring
- Test drift detection
- Test security controls
- Review security test results
- Interview key personnel
Audit Outputs:
- Annual Accuracy, Robustness, and Security Audit Report
- Findings and recommendations
- Corrective action plans for deficiencies
5.3 External Audit / Regulatory Inspection
Preparation:
- Maintain audit-ready documentation at all times
- Designate Chief Technology Officer and IT Security Manager as regulatory liaisons
- Prepare standard response procedures for authority requests
Provide to Auditors/Regulators:
- Accuracy requirements and test results
- Robustness requirements and test results
- Security requirements and test results
- Threat models
- Performance monitoring reports
- Security test reports
- Internal audit reports
- Evidence of controls execution
Authority Request Response:
- Acknowledge request within 1 business day
- Provide requested documentation within 5 business days
- Coordinate through Legal, Chief Technology Officer, and IT Security Manager
- Document all interactions with authorities
ROLES AND RESPONSIBILITIES
6.1 RACI Matrix
| Activity | Chief Technology Officer | AI System Owner | Data Science | IT Security Manager | QA/Testing | Operations |
|---|---|---|---|---|---|---|
| Accuracy Requirements | R/A | A | R | I | C | I |
| Accuracy Testing | R | A | R | I | R | I |
| Accuracy Monitoring | R | A | C | I | I | R |
| Robustness Requirements | R | A | R | C | C | I |
| Robustness Testing | R | A | R | C | R | I |
| Drift Detection | R | A | R | I | I | C |
| Security Requirements | R | A | C | R/A | I | I |
| Security Testing | R | A | C | R | R | I |
RACI Legend:
- R = Responsible (does the work)
- A = Accountable (ultimately answerable)
- C = Consulted (provides input)
- I = Informed (kept up-to-date)
6.2 Role Descriptions
Chief Technology Officer
- Primary Responsibility: Owns accuracy, robustness, and security framework
- Key Activities:
- Establishes requirements framework
- Approves requirements
- Monitors compliance
- Reports metrics
- Required Competencies: EU AI Act Article 15, AI system architecture, performance management
AI System Owner
- Primary Responsibility: Accountable for accuracy, robustness, and security of their AI system
- Key Activities:
- Ensures requirements defined
- Ensures testing completed
- Monitors performance
- Participates in reviews
- Required Competencies: AI system knowledge, performance requirements
Data Science
- Primary Responsibility: Implements accuracy and robustness requirements
- Key Activities:
- Defines accuracy/robustness requirements
- Implements models meeting requirements
- Conducts testing
- Monitors performance
- Required Competencies: Machine learning, model development, performance optimization
IT Security Manager
- Primary Responsibility: Owns security requirements and testing
- Key Activities:
- Defines security requirements
- Conducts threat modeling
- Manages security testing
- Monitors security
- Required Competencies: Cybersecurity, AI security, threat modeling
QA/Testing
- Primary Responsibility: Conducts testing
- Key Activities:
- Plans testing
- Executes tests
- Reports results
- Required Competencies: Testing methodologies, quality assurance
Operations
- Primary Responsibility: Monitors performance in production
- Key Activities:
- Monitors accuracy
- Monitors drift
- Alerts on issues
- Required Competencies: Operations monitoring, alerting
EXCEPTIONS
7.1 Exception Philosophy
Accuracy, robustness, and security are critical regulatory compliance activities for high-risk AI systems. Exceptions are granted restrictively and only where compensating controls adequately mitigate risks.
7.2 Allowed Exceptions
The following exceptions may be granted with proper justification and approval:
| Exception Type | Justification Required | Maximum Duration | Approval Authority | Compensating Controls |
|---|---|---|---|---|
| Reduced Accuracy Threshold (Minimal-Risk AI) | AI system clearly minimal-risk; lower accuracy acceptable | Permanent | Chief Technology Officer | Document rationale; Annual re-confirmation |
| Extended Security Testing Timeline | Resource constraints prevent timely testing | 30 days | Chief Technology Officer + IT Security Manager | Interim security measures; Accelerated plan |
7.3 Prohibited Exceptions
The following exceptions cannot be granted under any circumstances:
❌ Skipping accuracy requirements for high-risk AI - Mandatory per Article 15(1), no exceptions
❌ Skipping robustness requirements for high-risk AI - Mandatory per Article 15(4), no exceptions
❌ Skipping security requirements for high-risk AI - Mandatory per Article 15(5), no exceptions
❌ Deploying with accuracy below threshold - Creates safety and compliance risks
❌ Deploying with critical security vulnerabilities - Creates security risks
7.4 Exception Request Process
Step 1: Submit Exception Request
- Complete Exception Request Form (FORM-AI-EXCEPTION-001)
- Include business justification
- Propose compensating controls
- Specify duration requested
- Attach risk assessment
Step 2: Risk Assessment
- Chief Technology Officer assesses risk of granting exception
- Evaluates adequacy of compensating controls
- Documents residual risk
Step 3: Approval
- Route to appropriate approval authority based on exception type
- Chief Technology Officer approval: Minor exceptions
- Chief Technology Officer + AI Governance Committee: Significant exceptions
- AI Governance Committee: Critical exceptions
Step 4: Documentation and Monitoring
- Document exception in Exception Register
- Assign exception owner
- Set review date
- Monitor compensating controls
- Report exceptions quarterly to AI Governance Committee
Step 5: Exception Review and Closure
- Review exception at specified review date
- Assess if exception still needed
- Close exception when normal requirements met
- Document lessons learned
ENFORCEMENT
8.1 Non-Compliance Consequences
| Violation | Severity | Consequence | Remediation Required |
|---|---|---|---|
| High-risk AI without accuracy requirements | Critical | Immediate suspension until requirements defined | Define requirements within 5 business days; Root cause analysis |
| Deploying with accuracy below threshold | Critical | Immediate halt deployment; Compliance gap assessment | Improve accuracy; Re-test; Re-approve |
| Missing robustness requirements | High | Escalation to AI Governance Committee | Define requirements within 10 business days |
| Missing security requirements | Critical | Immediate suspension | Define requirements within 5 business days |
| Critical security vulnerabilities | Critical | Immediate correction; Security investigation | Remediate within 24 hours; Security review |
| Missing drift detection | Medium | Written warning | Implement drift detection within 10 business days |
8.2 Escalation Procedures
Level 1: Chief Technology Officer
- Minor procedural violations
- Documentation deficiencies
- Timeline delays < 5 days
- Action: Written warning, corrective action required
Level 2: Chief Technology Officer + AI Governance Committee
- Repeated violations
- Missing requirements
- Performance below thresholds
- Action: Formal review, corrective action plan, management notification
Level 3: AI Governance Committee
- High-risk AI without requirements
- Critical security vulnerabilities
- Critical compliance failures
- Action: Immediate AI system suspension, investigation, disciplinary action
Level 4: Executive Management + Legal
- Potential regulatory enforcement action
- Significant legal liability
- Reputational risk
- Action: Executive crisis management, legal strategy, regulatory engagement
8.3 Immediate Escalation Triggers
Escalate immediately to AI Governance Committee + Legal if:
- ⚠️ High-risk AI system operating without accuracy/robustness/security requirements
- ⚠️ Critical security vulnerability identified
- ⚠️ Security breach or attack
- ⚠️ Regulatory inquiry or inspection related to accuracy/robustness/security
- ⚠️ Significant accuracy degradation affecting safety
8.4 Disciplinary Actions
Individuals responsible for violations may be subject to:
- Verbal or written warning
- Mandatory retraining
- Performance improvement plan
- Reassignment of responsibilities
- Suspension (with pay during investigation)
- Termination (for egregious violations, e.g., knowingly deploying with critical vulnerabilities)
Factors Considered:
- Intent (knowing violation vs. honest mistake)
- Severity of violation
- Impact (actual or potential)
- Cooperation with remediation
- Prior violation history
KEY PERFORMANCE INDICATORS (KPIs)
9.1 Accuracy, Robustness, and Security KPIs
| KPI ID | KPI Name | Definition | Target | Measurement Method | Frequency | Owner | Reporting To |
|---|---|---|---|---|---|---|---|
| KPI-ARS-001 | Accuracy Requirements Coverage | % of high-risk AI with accuracy requirements | 100% | (# AI with requirements / # high-risk AI) × 100 | Monthly | Chief Technology Officer | AI Governance Committee |
| KPI-ARS-002 | Accuracy Threshold Compliance | % of AI systems meeting accuracy thresholds | 100% | (# AI meeting thresholds / # total AI) × 100 | Daily | Chief Technology Officer | Management |
| KPI-ARS-003 | Accuracy Stability | Accuracy variation over time | < 2% | Standard deviation of accuracy | Weekly | Chief Technology Officer | Management |
| KPI-ARS-004 | Robustness Requirements Coverage | % of high-risk AI with robustness requirements | 100% | (# AI with requirements / # high-risk AI) × 100 | Monthly | Chief Technology Officer | AI Governance Committee |
| KPI-ARS-005 | Robustness Score | Composite robustness score | ≥90% | Weighted average of robustness metrics | Monthly | Chief Technology Officer | Management |
| KPI-ARS-006 | Drift Detection Coverage | % of AI systems with drift detection | 100% | (# AI with drift detection / # total AI) × 100 | Monthly | Chief Technology Officer | Management |
| KPI-ARS-007 | Drift Detection Rate | Number of drift events detected | Monitor trends | Count of drift events | Weekly | Chief Technology Officer | Management |
| KPI-ARS-008 | Security Requirements Coverage | % of high-risk AI with security requirements | 100% | (# AI with requirements / # high-risk AI) × 100 | Monthly | IT Security Manager | AI Governance Committee |
| KPI-ARS-009 | Security Vulnerability Count | Number of critical vulnerabilities | 0 | Count of critical vulnerabilities | Monthly | IT Security Manager | AI Governance Committee |
| KPI-ARS-010 | Security Testing Completion | % of required security tests completed | 100% | (# tests completed / # required tests) × 100 | Quarterly | IT Security Manager | Management |
9.2 KPI Dashboards and Reporting
Real-Time Dashboard (Chief Technology Officer and IT Security Manager access)
- Current accuracy metrics
- Robustness scores
- Drift detection status
- Security vulnerability status
- Performance trends
Monthly Management Report
- KPI-ARS-001, 002, 003, 004, 005, 006, 007, 008, 009
- Trend analysis (vs. previous month)
- Issues and risks
- Planned actions
Quarterly AI Governance Committee Report
- All KPIs
- Accuracy performance assessment
- Robustness performance assessment
- Security posture assessment
- Internal audit findings (if conducted)
- Exception register review
Annual Executive Report
- Full-year KPI performance
- Performance maturity assessment
- Strategic recommendations
- Regulatory outlook
9.3 KPI Thresholds and Alerts
| KPI | Green (Good) | Yellow (Warning) | Red (Critical) | Alert Action |
|---|---|---|---|---|
| Accuracy Threshold Compliance | 100% | 95-99% | < 95% | Red: Immediate escalation to AI Governance Committee Chair |
| Accuracy Stability | < 2% | 2-5% | > 5% | Red: Escalate to AI Governance Committee |
| Robustness Score | ≥90% | 85-89% | < 85% | Yellow: Improvement plan; Red: Escalate to AI Governance Committee |
| Security Vulnerability Count | 0 | 1-2 | > 2 | Red: Immediate escalation to IT Security Manager + AI Governance Committee |
TRAINING REQUIREMENTS
10.1 Training Program Overview
All personnel involved in accuracy, robustness, and security must complete role-specific training to ensure competency in EU AI Act Article 15 requirements, performance management, and security practices.
10.2 Role-Based Training Requirements
| Role | Training Course | Duration | Content | Frequency | Assessment Required |
|---|---|---|---|---|---|
| Chief Technology Officer | Performance Management Expert Training | 16 hours | EU AI Act Article 15; Accuracy requirements; Robustness requirements; Security requirements | Initial + annually | Yes - Written exam (≥90%) |
| Data Scientists | Accuracy and Robustness Training | 12 hours | Accuracy metrics; Robustness testing; Drift detection; Model optimization | Initial + annually | Yes - Practical exercise |
| IT Security Manager | AI Security Expert Training | 16 hours | AI-specific security threats; Security testing; Threat modeling; Security controls | Initial + annually | Yes - Written exam (≥90%) |
| QA/Testing | Performance Testing Training | 8 hours | Accuracy testing; Robustness testing; Security testing; Test methodologies | Initial + annually | Yes - Practical exercise |
| AI System Owners | Performance Overview | 4 hours | Accuracy requirements; Robustness requirements; Security requirements; Responsibilities | At onboarding + annually | Yes - Knowledge check (≥80%) |
| All AI Development Staff | Performance Awareness | 2 hours | Accuracy basics; Robustness basics; Security basics; Requirements | At onboarding + annually | Yes - Knowledge check (≥80%) |
10.3 Training Content by Topic
EU AI Act Article 15 Requirements
- Accuracy requirements (Article 15(1))
- Robustness requirements (Article 15(4))
- Security requirements (Article 15(5))
- Compliance obligations
Accuracy Management
- Accuracy metrics
- Accuracy testing
- Accuracy monitoring
- Performance optimization
Robustness Management
- Robustness dimensions
- Robustness testing
- Drift detection
- Model stability
AI Security
- AI-specific security threats
- Security controls
- Security testing
- Threat modeling
10.4 Training Delivery Methods
Initial Training:
- Instructor-led classroom or virtual training
- Includes interactive exercises and case studies
- Hands-on practice with testing tools
- Group discussions of complex scenarios
Annual Refresher:
- E-learning modules for core content review
- Live update sessions for regulatory changes
- Case study reviews of recent performance activities
- Knowledge assessment
On-the-Job Training:
- Mentoring for new performance staff
- Job shadowing during testing
- Supervised testing for first 5 AI systems
Just-in-Time Training:
- Quick reference guides and job aids
- Video tutorials on specific topics
- Help desk support from experienced staff
10.5 Training Effectiveness Measurement
Assessment Methods:
- Written exams for knowledge retention
- Practical exercises for skill application
- On-the-job observations for competency validation
- Feedback surveys for training quality
Competency Validation:
- Data Scientists: Must demonstrate ability to define requirements and conduct testing for 1 sample AI system with 100% compliance before independent work
- All staff: Must pass knowledge assessments with minimum required scores
Training Metrics:
| Metric | Target | Frequency |
|---|---|---|
| Training completion rate | 100% | Quarterly |
| Assessment pass rate (first attempt) | ≥ 90% | Per training |
| Training effectiveness score (survey) | ≥ 4.0/5.0 | Per training |
| Time to competency (Data Scientists) | < 30 days | Per person |
10.6 Training Records
Records Maintained:
- Training attendance records
- Assessment scores
- Competency validations
- Refresher training completion
- Individual training transcripts
Retention: 10 years (to align with EU AI Act documentation retention)
Access: HR, Chief Technology Officer, Internal Audit, Competent Authorities (upon request)
DEFINITIONS
| Term | Definition | Source |
|---|---|---|
| Accuracy | Degree to which AI system outputs are correct | EU AI Act Article 15(1) |
| Robustness | Ability of AI system to maintain performance despite errors, faults, or adversarial conditions | EU AI Act Article 15(4) |
| Cybersecurity | Protection of AI systems against cybersecurity threats | EU AI Act Article 15(5) |
| Precision | % of positive predictions that are correct | This Standard |
| Recall | % of actual positives correctly identified | This Standard |
| F1 Score | Harmonic mean of precision and recall | This Standard |
| ROC-AUC | Area under Receiver Operating Characteristic curve | This Standard |
| Data Drift | Change in input data distribution over time | This Standard |
| Concept Drift | Change in relationship between inputs and outputs over time | This Standard |
| Adversarial Attack | Malicious input designed to fool AI model | This Standard |
| Model Extraction | Attack to steal model through queries | This Standard |
| Data Poisoning | Attack to corrupt training data | This Standard |
| Model Inversion | Attack to extract training data from model | This Standard |
| Backdoor Attack | Attack to introduce hidden malicious behavior | This Standard |
LINK WITH AI ACT AND ISO42001
12.1 EU AI Act Regulatory Mapping
This standard implements the following EU AI Act requirements:
| EU AI Act Provision | Article | Requirement Summary | Implemented By (Controls) |
|---|---|---|---|
| Accuracy, Robustness and Cybersecurity | Article 15 | Requirements for high-risk AI | All controls (ARS-001 through ARS-008) |
| Accuracy | Article 15(1) | Appropriate accuracy levels | ARS-001, ARS-002, ARS-003 |
| Robustness | Article 15(4) | Resilience to errors and faults | ARS-004, ARS-005, ARS-006 |
| Cybersecurity | Article 15(5) | Resilience against cybersecurity threats | ARS-007, ARS-008 |
12.2 ISO/IEC 42001:2023 Alignment
This standard aligns with ISO/IEC 42001:2023 as follows:
| ISO 42001 Clause | Requirement | Implementation in This Standard |
|---|---|---|
| Clause 6.1.2: AI system impact assessment | Assess accuracy, robustness, security impacts | ARS-001, ARS-004, ARS-007 |
| Clause 8.2: AI system risk assessment | Accuracy, robustness, security in risk management | All controls |
| Clause 9.1: Monitoring, measurement, analysis, and evaluation | Monitor performance | ARS-003, ARS-006 |
12.3 Relationship to Other Standards
This accuracy, robustness, and security standard integrates with other AI Act standards:
| Related Standard | Integration Point | Rationale |
|---|---|---|
| STD-AI-001: Classification | Classification determines if requirements apply | High-risk AI requires Article 15 requirements |
| STD-AI-002: Risk Management | Accuracy, robustness, security risks in risk assessment | Risk management identifies performance risks |
| STD-AI-004: Technical Documentation | Performance metrics documented in Annex IV | Performance information in technical documentation |
| STD-AI-013: Incident Management | Performance issues may trigger incidents | Performance degradation may be incidents |
12.4 References and Related Documents
EU AI Act (Regulation (EU) 2024/1689):
- Article 15: Accuracy, Robustness and Cybersecurity
- Article 15(1): Accuracy
- Article 15(3): Accuracy Declaration in Instructions for Use (cross-reference to STD-AI-006 Control TRANS-001)
- Article 15(4): Robustness
- Article 15(5): Cybersecurity
ISO/IEC Standards:
- ISO/IEC 42001:2023: Information technology — Artificial intelligence — Management system
- ISO/IEC 23894:2023: Information technology — Artificial intelligence — Guidance on risk management
- ISO/IEC 27001:2022: Information security management systems
Internal Documents:
- POL-AI-001: Artificial Intelligence Policy (parent policy)
- STD-AI-001: AI System Classification Standard
- STD-AI-002: AI Risk Management Standard
- STD-AI-004: AI Technical Documentation Standard
- PROC-AI-ARS-001, -002, -003, -004: Performance procedures
APPROVAL AND AUTHORIZATION
| Role | Name | Title | Signature | Date |
|---|---|---|---|---|
| Prepared By | David Lee | Chief Technology Officer | _________________ | ________ |
| Reviewed By | IT Security Manager | IT Security Manager | _________________ | ________ |
| Reviewed By | Sarah Johnson | AI Act Program Manager | _________________ | ________ |
| Reviewed By | Jane Doe | Chief Strategy & Risk Officer | _________________ | ________ |
| Approved By | Jane Doe | AI Governance Committee Chair | _________________ | ________ |
Effective Date: 2025-08-01
Next Review Date: 2026-08-01
Review Frequency: Annually or upon regulatory change
END OF STANDARD STD-AI-008
This standard is a living document. Feedback and improvement suggestions should be directed to the Chief Technology Officer.
Standard ID
STD-AI-008
Version
1.0
Status
draftOwner
CTO
Effective Date
2025-08-01
Applicability
High-risk AI systems