ISO/IEC 42001:2023 is rapidly becoming the gold standard for enterprise AI management. However, many risk teams are falling into a familiar compliance trap: treating certification as a guarantee of decision integrity.
1. Static Audits vs. Millisecond Drift
An ISO 42001 audit inspects your policies, training records, and risk assessment registers. It does not inspect the token sequence generated at 2:14 AM when an LLM recommends an unauthorized financial credit limit.
2. Policy Registers Aren't Evidence Ledgers
Listing risk controls in a spreadsheet satisfies governance documentation requirements, but it fails to prove that an evidence boundary was enforced when a specific high-consequence decision was executed.
3. Human Oversight Demands Structural Gating
Clause 8.4 mandates human oversight. But if human operators are shown a pre-summarized AI verdict without dissent markers or evidentiary lineage, oversight becomes a rubber stamp.