Three references for one job.
Every AI compliance team has these three references on the bookshelf. None of them is binding by itself. The OECD AI Principles are a Council recommendation, OECD/LEGAL/0449. ISO/IEC 24028 is a Technical Report, the lowest deliverable rank in the ISO catalogue. The IAPP AIGP is a professional credential, awarded to individuals, not organisations. A defence counsel reading any one of them in isolation reads a non-binding text.
Read together, they are the methodology stack a Chief AI Officer reaches for when the regulator shows up. The OECD principles supply the values. ISO/IEC 24028 supplies the vocabulary that operationalises the values. The AIGP body of knowledge supplies the curriculum the human governing the system has internalised. The three references cover the same ground at three altitudes: principle, terminology, practice.
Coverage matters because all three appear by name in binding texts. Recital 7 of the EU AI Act, Regulation (EU) 2024/1689, cites the OECD Recommendation on Artificial Intelligence as the foundation the Union legal text builds on. The NIST AI Risk Management Framework references the OECD principles in its preface. US federal procurement guidance, in OMB M-24-10 and the successor M-25 series, references both the OECD principles and the NIST AI RMF as benchmarks for vendor evaluation. ISO/IEC 24028's vocabulary is what the certifiable management system standard, ISO/IEC 42001:2023, reuses in its Annex A controls. The AIGP curriculum is the only mainstream credential aligned to the cross-jurisdiction body of work spanning all of the above.
This entry reads each reference at the level of detail a compliance officer needs to map evidence to artefact. OECD principles supply the values. ISO 24028 supplies the threat taxonomy. AIGP supplies the practitioner.
OECD AI Principles · the 5 principles.
The OECD AI Principles, at the values layer, are five sentences. Verbatim from OECD/LEGAL/0449:
The five values were adopted by the OECD Council on 22 May 2019, the first intergovernmental standard for trustworthy AI. Forty-six jurisdictions have adhered to the recommendation as of the May 2024 revision: thirty-eight OECD members and eight partner economies including Argentina, Brazil, Egypt, Malta, Peru, Romania, Singapore and Ukraine. The G20 endorsed the same principles in its 2019 AI Principles, which gives the document reach into China, India, Indonesia, Russia, Saudi Arabia and South Africa as a soft-law floor.
Recital 7 of Regulation (EU) 2024/1689 cites the recommendation by name and states that the Union legal text builds on the OECD principles to define a coherent legal text at Union level. The NIST AI Risk Management Framework cites the principles in its preface as foundational to the Map, Measure, Manage and Govern functions. A regulator that opens with "your system shall be transparent and accountable" without further citation is, ninety percent of the time, citing OECD AI principle 3 and OECD AI principle 5 by reference.
The values layer maps to a record. Principle 3 maps to a per-decision rationale. Principle 4 maps to an adversarial robustness eval per release. Principle 5 maps to a named-owner record per decision. Compliance is a question about the records that exist under each value, not about the values themselves.
OECD recommendations · the 5 to governments.
The principles bind values; the recommendations bind state action. The five recommendations to governments, verbatim:
These recommendations are the soft-law signposts every domestic AI regulator cites when justifying its rules. The EU AI Act preamble references items 3 and 5 in its co-operation language. The UK AI Safety Institute mandate, in operation since November 2023, references items 1 and 5. India's AI Mission programme, IndiaAI, references items 1 and 4 in its compute-and-skills allocation. Singapore's Model AI Governance Framework, second edition for generative AI, references item 3 in its self-positioning as an interoperable governance text.
Item 4, "building human capacity and preparing for labour market transformation", is the recommendation that closes the loop with the AIGP credential. The AIGP curriculum is one literal answer to the recommendation: a human-capacity programme certifying individuals on the body of knowledge governments have endorsed. The recommendation does not name AIGP, but the credential is the most direct route to evidencing the recommendation in a covered organisation's training register.
The May 2024 update · generative AI.
The OECD's 2024 revision was a structural rewrite of the 2019 text to address generative and general-purpose AI. The five principles and five recommendations were retained verbatim. The supporting paragraphs were rewritten to add explicit attention to four areas the 2019 text predated.
The first is synthetic content provenance. The 2024 text adds language on disclosure of AI-generated content, content authenticity standards such as C2PA, and watermarking. The text does not mandate a specific provenance scheme but lifts the value into the principles' supporting commentary, which is the lever subsequent binding regulation pulls on. EU AI Act Article 50, on transparency obligations for providers and deployers of certain AI systems, is the binding instrument that operationalises this 2024 OECD addition.
The second is governance of foundation models. The 2024 revision adds language on systemic-risk assessment for general-purpose AI models and on cross-border co-operation in their evaluation. EU AI Act Articles 51 to 56 on general-purpose AI models, and the EU AI Office's General-Purpose AI Code of Practice (third draft published March 2025), are the binding and quasi-binding instruments that operationalise this 2024 OECD addition.
The third is the OECD definition of an AI system. The 2024 revision retains the November 2023 OECD definition, which was lifted into Article 3(1) of the EU AI Act and into NIST AI RMF: a machine-based system that, for explicit or implicit objectives, infers from the input it receives how to generate outputs such as predictions, content, recommendations or decisions that can influence physical or virtual environments. A team that aligns its system inventory to the OECD definition gets EU and US definitional alignment in one sentence.
The fourth is the relationship to digital identity, content authenticity, and democratic-process integrity. The 2024 revision is, in tone, the OECD acknowledging that the 2019 text underweighted the systemic-information risk that generative AI introduced. "OECD-aligned" now means "post-2024 OECD-aligned". A team that drafted its AI policy against the 2019 text has a refresh task on its register.
ISO/IEC 24028:2020 · the trustworthiness vocabulary.
ISO/IEC TR 24028:2020 was published by the joint ISO/IEC subcommittee SC 42 in May 2020 and remains the conceptual baseline most other ISO/IEC AI standards build on. The "TR" prefix is meaningful: a Technical Report is the lowest deliverable rank in the ISO catalogue, intended to deliver information without normative requirements. The trade-off is that 24028 is not certifiable. The advantage is that 24028 can describe the field without prescribing a single methodology, which is what made it the working dictionary downstream standards reuse.
The document delivers four artefacts a Chief AI Officer needs:
- Trustworthiness characteristics. Accuracy, availability, controllability, reliability, resilience, robustness, safety, security, transparency, privacy. Each is defined in clauses 5.1 to 5.10. These are the words ISO/IEC 42001's Annex A controls and ISO/IEC 23894's risk catalogue point at when they say "transparency" or "robustness".
- Threats to trustworthiness. Data poisoning, model evasion, adversarial inputs, distribution shift, oracle attacks, model extraction, model inversion, membership inference, transfer attacks, backdoor attacks, availability attacks. The threats list is 24028 § 6, the most-cited section of the document.
- Stakeholder roles. Developer, deployer, end user, regulator, third party. The roles align with EU AI Act Articles 25 to 27, which use the same divisions in different language.
- Lifecycle phases. Inception, design, development, verification, deployment, operation, retirement. Seven phases, used as tags downstream standards apply to artefacts.
24028 is the vocabulary 42001's Annex A controls operationalise. ISO/IEC 23894:2023, the AI risk management guidance, reuses the 24028 threat taxonomy verbatim. ISO/IEC 5338:2023, the AI lifecycle process standard, reuses the 24028 lifecycle phases verbatim. Reading 42001 without 24028 is reading a checklist without the dictionary.
The phrase "in a verifiable way" carries the load. Verifiability is the bridge from soft-law value to hard-law evidence. A regulator does not grade your trustworthiness; the regulator grades the records you produce that show, in the standard's terms, that the trustworthiness characteristics were tested, the threats were enumerated, and the lifecycle phases were tagged.
The threats list · what a Chief AI Officer must enumerate.
Section 6 of ISO/IEC 24028 catalogues the threat categories that an AI system must, at a minimum, have considered. The clause is not normative; the catalogue is widely treated as the lower bound for an organisational threat model. The categories, near-verbatim from § 6:
For each of the ten categories, an organisation needs an evidence-of-mitigation record per AI system. The record can be short. A two-line entry stating the category, the mitigation, the test that produced the evidence, and the date of the test is sufficient for a baseline submission. The Warrant adversarial-robustness eval at /blog/regulator-grade-evals is the per-decision instance of this record: each attestable action carries a per-action threat-mitigation check pointing at the adversarial-evaluation suite that ran for the release the decision was served on.
"Was the adversarial robustness eval run for this release?"
Yes or no, with eval-suite reference, eval-suite version, eval-suite output. This is the release-gate question.
"Did the threat-mitigation check fire on this specific action?"
The trace carries a per-action threat_mitigation_check field pointing at the eval-suite reference live at the time of the action. The auditor can re-run the suite against the historical artefact and reproduce the result.
The IAPP AIGP body of knowledge · 7 domains.
The International Association of Privacy Professionals launched the Artificial Intelligence Governance Professional credential in March 2024. The AIGP is the first professional certification for AI governance and is positioned as the AI-governance counterpart to the IAPP's CIPP for privacy. The credential examines a candidate against the AIGP body of knowledge, organised in seven domains. Domain titles, verbatim:
The seven domains are what an AIGP holder must defend, in practice, on a real AI system. Domain II is OECD-aligned: principle 2 on human rights, principle 3 on transparency, and principle 5 on accountability appear in the AIGP exam outline by reference. Domain III is ISO 24028 and ISO 5338-aligned: lifecycle phases, stakeholder roles, threat enumeration. Domain VI is the cross-jurisdiction landscape: EU AI Act, NIST AI RMF, sector-specific US guidance, UK pro-innovation paper, China generative-AI rules, India DPDP, Brazil PL 21/20, OECD principles. Domain VII is the enterprise-risk overlay: NIST AI RMF Govern / Map / Measure / Manage and ISO/IEC 23894 risk treatment.
The credential is necessary, not sufficient. An audit reads evidence, not credentials. The AIGP holder is the person who assembles and defends the evidence: the system inventory under Domain I, the impact assessment under Domain II, the threat-mitigation record under Domain III, the governance programme documentation under Domain IV, the regulatory mapping under Domain VI, the enterprise-risk register under Domain VII. A team with AIGP holders and no underlying evidence pipeline fails an audit no faster than a team with evidence and no credentials.
Three references, one evidence shape.
The three references resolve, at the artefact layer, to a small set of evidence fields. The mapping table makes the resolution explicit:
| Reference | What to evidence | Warrant field |
|---|---|---|
| OECD principle 3 · transparency | per-decision rationale + source attribution | trace.actions[].decision_rationale |
| OECD principle 4 · "Robustness, security and safety" | adversarial robustness eval per release | regulator_evidence.eval_suite_ref |
| OECD principle 5 · accountability | named-owner record per decision | metadata.accountable_owner_id |
| ISO 24028 § 6 threats | per-decision threat-mitigation check | trace.actions[].threat_mitigation_check |
| ISO 24028 lifecycle phase | phase tag per decision (operation vs. development) | metadata.lifecycle_phase |
| AIGP Domain III · lifecycle | full evidence-replay surface | regulator_evidence.audit_trail_pointer |
| AIGP Domain VI · laws + standards | regulator-mapping per decision | regulator_evidence.regimes_engaged |
The mapping shows that three references, each with hundreds of pages of supporting commentary, resolve at the bottom of the stack to seven evidence fields per attestable action. A Warrant package carrying these seven fields, independently verifiable without contacting Warrant, satisfies the soft-law tier in one document. The same document carries the binding-tier mappings for EU AI Act Articles 12 and 13, NYDFS § 500.6, SR 11-7, FCA Consumer Duty Principle 12, RBI FREE-AI, SEBI Retail Algo, India DPDP, MAS FEAT.
{
"action_id": "2026-06-12T14:23:11.482Z-7de8ce",
"trace": {
"actions": [
{
"actor": "underwriter-agent-v3.2.1",
"decision_rationale": "applicant qualifies under SBA 7(a) ...", // OECD P3
"threat_mitigation_check": { // ISO 24028 § 6
"eval_suite_ref": "eval-suite-9f1c...",
"categories_passed": ["T1", "T2", "T9", "T10"]
}
}
]
},
"metadata": {
"accountable_owner_id": "warrant-eu-prod-01-owner-0064", // OECD P5
"lifecycle_phase": "operation" // ISO 24028 § 5
},
"regulator_evidence": {
"eval_suite_ref": "eval-suite-9f1c...", // OECD P4
"audit_trail_pointer": "warrant://traces/7de8ce...", // AIGP D-III
"regimes_engaged": ["EU-AI-Act-Art-12", "SR-11-7"] // AIGP D-VI
}
}
The same record, independently verifiable without contacting Warrant, satisfies the OECD values layer, the ISO 24028 vocabulary layer, the AIGP curriculum layer, and the binding-regulator layer. The architectural detail of the four layers, and how each one verifies, lives at /blog/four-layer-evidence-stack.
Where the soft-law tier sits in the wider stack.
The three references read in this entry are the soft-law tier of a three-tier stack. The other two tiers sit above and below.
┌──────────────────────────────────┐
│ Tier 3 · Binding regulation │ EU AI Act · NYDFS · SR 11-7
│ │ FCA Consumer Duty · RBI FREE-AI
│ │ SEBI Retail Algo · India DPDP
│ │ MAS FEAT · NDPR
├──────────────────────────────────┤
│ Tier 2 · Standards │ ISO/IEC 42001:2023 · 23894:2023
│ │ ISO/IEC 5338 · 5469 · 38507
│ │ CEN-CENELEC hENs (in progress)
├──────────────────────────────────┤
│ Tier 1 · Soft law (this entry) │ OECD AI Principles
│ │ ISO/IEC 24028 (TR · vocabulary)
│ │ NIST AI RMF (voluntary)
│ │ IAPP AIGP (credential)
└──────────────────────────────────┘
Tier 1 is non-binding by design. The OECD recommendation is a Council instrument with no treaty force. ISO/IEC 24028 is a Technical Report, not a certifiable standard. NIST AI RMF is a voluntary text. The AIGP is a professional credential. None of the four binds an organisation by force of law on its own.
Tier 2 is voluntary but certifiable. ISO/IEC 42001:2023 is the certifiable AI Management System standard. ISO/IEC 23894:2023 is the AI risk-management guidance, intended as a sector overlay on ISO 31000. ISO/IEC 5338:2023 is the AI lifecycle process standard. ISO/IEC 5469 (functional safety in AI), ISO/IEC 38507 (AI governance for boards), and the CEN-CENELEC harmonised European standards (hENs) currently in development for the EU AI Act sit in this tier. Tier 2 standards reuse Tier 1 vocabulary.
Tier 3 is binding. EU AI Act, NYDFS Part 500, Federal Reserve SR 11-7 (re-issued as SR 26-2), FCA Consumer Duty, RBI FREE-AI guidance, SEBI Retail Algo Framework, India DPDP, MAS FEAT principles, Nigerian NDPR. Tier 3 cites Tier 1 in recitals and reuses Tier 2 vocabulary in operative clauses.
The Warrant evidence package is engineered to satisfy all three tiers in one document, independently verifiable without contacting Warrant. The same record carries the OECD principle 3 and 5 fields, the ISO 24028 § 6 threat-mitigation field, the AIGP Domain III audit-trail pointer, and the EU AI Act Article 12 record-keeping fields. A regulator at any tier opens the same document.
For the AIGP candidate · the practical bookshelf.
The AIGP exam outline lists primary references at a high level; in practice, the body of work an AIGP must engage with is bigger than the exam outline and varies by the candidate's regulatory exposure. The bookshelf, with the Warrant deep-dive entry where one exists:
- OECD AI Principles · 2019 / 2024. The five principles, the five recommendations, the 2024 update on generative AI. This entry.
- ISO/IEC 42001:2023 · AIMS. The certifiable AI Management System standard. Annex A controls. Sister entry at /blog/iso-iec-42001-ai-management-system.
- ISO/IEC 23894:2023 · risk guidance. The AI risk-management guidance, sector overlay on ISO 31000. Reuses ISO 24028 threat taxonomy.
- ISO/IEC 24028:2020 · trustworthiness vocabulary. The dictionary the other ISO AI standards reuse. This entry.
- NIST AI RMF 1.0 · January 2023. The Govern / Map / Measure / Manage functions. Sister entry at /blog/nist-ai-rmf.
- NIST AI RMF Generative AI Profile · July 2024. The generative-AI overlay on the 2023 voluntary text.
- EU AI Act · Regulation (EU) 2024/1689 + Annex IV. Recital 7 cites OECD; Annex IV is the technical-documentation list. Per-article entries at /blog/eu-ai-act-article-12 and /blog/eu-ai-act-article-13.
- GDPR · Regulation (EU) 2016/679. The data-protection foundation any AI-governance person reasons against. Article 22 on automated decision-making is the AI-relevant clause.
- Sector-specific. NYDFS Part 500 (cyber and audit-trail · entry at /blog/nydfs-standard-logs), Federal Reserve SR 11-7 / SR 26-2 (model risk · entry at /blog/sr-11-7-model-risk), FCA Consumer Duty Principle 12 (UK retail conduct · entry at /blog/fca-consumer-duty-principle-12), RBI FREE-AI, SEBI Retail Algo, India DPDP, MAS FEAT, Hong Kong HKMA principles, Australia voluntary AI Safety Standard.
The bookshelf is what an AIGP holder reads against in practice. Of the seventeen items on the list, three are the soft-law tier covered in this entry, four are the standards tier, and ten are the binding-regulation tier across jurisdictions. The Warrant blog index at /blog carries a per-item entry for each of the binding instruments where one exists. The seventeenth, the OECD definition of an AI system, is the connective tissue that lets a system inventory be read against any of the tiers.
Closing · what Warrant evidences.
Every Warrant evidence package, on every attestable action, carries the seven fields the synthesis table prescribes. The OECD principle 3 transparency record sits at trace.actions[].decision_rationale. The OECD principle 4 robustness record sits at regulator_evidence.eval_suite_ref. The OECD principle 5 accountability record sits at metadata.accountable_owner_id. The ISO 24028 § 6 threat-mitigation record sits at trace.actions[].threat_mitigation_check. The ISO 24028 lifecycle-phase tag sits at metadata.lifecycle_phase. The AIGP Domain III audit-trail pointer sits at regulator_evidence.audit_trail_pointer. The AIGP Domain VI regulator-mapping sits at regulator_evidence.regimes_engaged.
A compliance officer presenting the package in a regulator meeting can speak to each field by reference to its source instrument. The same officer at an internal AI ethics review can point at the same fields and read the OECD principles into the record. The same officer preparing for AIGP renewal can point at the same fields and read the body-of-knowledge domains into the record. One artefact, three readings.
The synthesis is not novel. Every mature AI compliance practice converges on a small set of evidence fields covering values, vocabulary, and curriculum. The novelty in the Warrant package is that each field becomes independently verifiable without contacting Warrant, so that, when the audit lands two years after the action, the evidence reads as it read on the day. The full attestation rationale and four-layer architecture are at /blog/four-layer-evidence-stack.
The soft-law tier does not bind. The records the soft-law tier prescribes do bind, the moment a binding regulator opens an inquiry. Read the three references on the bookshelf. Build the seven fields into the trace. Make the result independently verifiable without contacting Warrant. The audit, when it comes, reads the document and closes the file.
Questions a compliance officer asks first.
Read the source directly.
- OECD AI Principles, OECD/LEGAL/0449, 2019 / 2024 →
- ISO/IEC TR 24028:2020, Overview of trustworthiness in artificial intelligence →
- IAPP AIGP credential and body of knowledge →
- EU AI Act, Regulation (EU) 2024/1689, Recital 7 (OECD reference) →
- NIST AI Risk Management Framework, AI RMF 1.0 →
- ISO/IEC 42001:2023, AI management system →
- ISO/IEC 23894:2023, AI risk management guidance →
- Warrant · the four-layer evidence stack, and how a record verifies →