AI Roles in ISO 42001: Provider, Producer, Customer, Partner
ISO 42001 defines distinct roles in the AI ecosystem. Understanding which role(s) your organization plays is essential for determining scope, responsibilities, and applicable controls.
Key Takeaways
| Point | Summary |
|---|---|
| AI Provider | Organizations developing AI systems for others to use |
| AI Producer | Organizations that design, develop, or modify AI systems (includes developers, deployers, operators) |
| AI Customer | Organizations that procure AI systems from providers |
| AI Partner | Organizations in the AI supply chain (data providers, trainers, consultants) |
| Multiple roles | Organizations often play multiple roles simultaneously |
| Scope impact | Your role determines which ISO 42001 requirements apply |
Quick Answer: ISO 42001 defines four main roles: AI Provider (develops AI for others), AI Producer (internal teams building/modifying AI), AI Customer (procures AI systems), and AI Partner (supply chain participants). Most organizations developing AI products are both Providers and Producers. Your roles determine your certification scope.
The Four AI Roles
AI Provider
An AI Provider develops AI systems intended for use by others:
| Characteristic | Description |
|---|---|
| Definition | Organization that develops AI systems for external parties |
| Examples | AI platform vendors, ML infrastructure companies, AI SaaS providers |
| Responsibilities | System design, training, testing, documentation, support |
| ISO 42001 relevance | Full scope typically applies |
Common AI Provider activities:
- Building AI platforms and APIs
- Creating AI-powered products for sale/licensing
- Developing AI models for customers
- Providing AI infrastructure services
ISO 42001 obligations for Providers:
| Area | Requirement |
|---|---|
| Design | Responsible AI system design (Annex A.6) |
| Data | Training data quality and governance (Annex A.7) |
| Documentation | Information for users and interested parties (Annex A.8) |
| Support | Ongoing assistance and incident handling |
| Monitoring | Post-deployment performance tracking |
AI Producer
ISO 42001 introduces the concept of AI Producer to cover various roles involved in creating AI systems:
| Producer Role | Activities |
|---|---|
| AI Developer | Designs, codes, and builds AI systems |
| AI Designer | Creates AI system architecture and requirements |
| AI Operator | Manages AI system operations |
| AI Tester | Validates and verifies AI systems |
| AI Deployer | Puts AI systems into production |
Understanding the distinction:
- Provider = Organization-level role (you provide AI to others)
- Producer = Functional role (people/teams creating AI)
An organization that is an AI Provider will have AI Producers within it.
ISO 42001 for Producers:
| Responsibility | Coverage |
|---|---|
| Competence | Required skills and training (Clause 7.2) |
| Awareness | Understanding of AI policies and impacts (Clause 7.3) |
| Resources | Adequate tools and infrastructure (Clause 7.1) |
| Processes | Following defined AI development procedures |
AI Customer
An AI Customer procures AI systems from providers:
| Characteristic | Description |
|---|---|
| Definition | Organization that acquires AI systems for their own use |
| Examples | Enterprises using AI platforms, businesses with AI tools |
| Responsibilities | Appropriate use, integration, monitoring |
| ISO 42001 relevance | Limited scope, focus on usage governance |
AI Customer responsibilities under ISO 42001:
| Area | Responsibility |
|---|---|
| Vendor management | Selecting appropriate AI providers (Annex A.10) |
| Appropriate use | Using AI within intended parameters (Annex A.9) |
| Human oversight | Maintaining appropriate supervision |
| Incident reporting | Communicating issues to providers |
| User training | Ensuring proper use by employees |
When AI Customers need ISO 42001:
- If you're also developing AI (then you're a Producer too)
- If you're deploying AI in high-risk contexts
- If customers require AI governance from you
- If regulatory requirements demand it
AI Partner
AI Partners are organizations in the AI supply chain that support providers and producers:
| Partner Type | Role |
|---|---|
| Data providers | Supply training data |
| Annotation services | Label and enrich datasets |
| Training services | Provide compute and training capabilities |
| Consultants | Advise on AI development |
| Infrastructure providers | Cloud and compute resources |
| Testing services | Third-party AI validation |
ISO 42001 relevance for Partners:
| Consideration | Impact |
|---|---|
| Direct certification | Partners may pursue certification for competitive advantage |
| Customer requirements | AI Providers may require partners to meet ISO 42001 controls |
| Contractual obligations | Security and quality requirements in agreements |
Mapping Roles to Your Organization
Assessment Questions
Are you an AI Provider?
- Do you sell/license AI systems to other organizations?
- Do you provide AI APIs or platforms externally?
- Do customers use your AI systems as part of their products?
Do you have AI Producers?
- Do you have teams developing AI/ML systems?
- Do you train or fine-tune models?
- Do you curate or create training datasets?
- Do you deploy AI systems to production?
Are you an AI Customer?
- Do you procure AI systems from external vendors?
- Do you use third-party AI APIs in your products?
- Do you license AI technology from others?
Are you an AI Partner?
- Do you provide data, training, or support services to AI developers?
- Are you part of AI supply chains without building AI yourself?
Common Role Combinations
| Organization Type | Typical Roles |
|---|---|
| AI SaaS startup | Provider + Producer |
| Enterprise building internal AI | Producer + Customer |
| AI platform company | Provider + Producer |
| Company using AI APIs | Customer only |
| Data labeling service | Partner |
| ML consulting firm | Partner (or Producer for client projects) |
Example: AI SaaS Startup
Role Mapping Example: AI Analytics SaaS
────────────────────────────────────────────────────
AI Provider:
└── Provides AI analytics platform to customers
AI Producer:
├── Engineering team develops ML models
├── Data scientists curate training data
├── ML engineers deploy to production
└── QA tests model performance
AI Customer:
└── Uses cloud AI services (e.g., AWS Bedrock) for some features
AI Partners:
├── Cloud infrastructure provider
├── Annotation service for training data
└── Security testing vendor
Role-Based ISO 42001 Scope
Provider Scope (Most Comprehensive)
If you're an AI Provider, your AIMS scope typically includes:
| Area | Scope Element |
|---|---|
| Systems | All AI systems provided to customers |
| Life cycle | Design through deployment and support |
| Data | Training data, operational data |
| Documentation | User documentation, technical docs |
| Support | Customer assistance, incident handling |
Applicable Annex A Controls:
| Control Area | Relevance |
|---|---|
| A.2 AI Policies | Required |
| A.3 Internal organization | Required |
| A.4 Resources | Required |
| A.5 Impact assessment | Required |
| A.6 System life cycle | Required |
| A.7 Data for AI systems | Required |
| A.8 Information for interested parties | Required |
| A.9 Use of AI systems | Required |
| A.10 Third-party relationships | Required |
Producer-Only Scope
If you develop AI for internal use only (not a Provider):
| Area | Scope Element |
|---|---|
| Systems | Internal AI systems |
| Life cycle | Development and deployment |
| Data | Training and operational data |
| Users | Internal users and stakeholders |
Potentially excludable:
- A.8 may be simplified (internal stakeholders only)
- A.10 may focus on suppliers rather than customers
Customer Scope (Limited)
If you're primarily an AI Customer with minimal development:
| Area | Scope Element |
|---|---|
| Vendor management | AI provider assessment and monitoring |
| Usage governance | Policies for AI tool use |
| Integration | How AI is embedded in processes |
Note: Pure AI Customers may not need ISO 42001 certification. Internal governance and vendor due diligence may suffice. See Who needs ISO 42001.
Responsibilities by Role
Provider Responsibilities
| Responsibility | Description |
|---|---|
| Safe AI systems | Design and build AI that minimizes harm |
| Transparency | Provide clear documentation on AI capabilities and limitations |
| Support | Assist customers in appropriate use |
| Monitoring | Track AI performance post-deployment |
| Updates | Address issues and improve systems |
| Communication | Inform customers of changes and incidents |
Producer Responsibilities
| Responsibility | Description |
|---|---|
| Follow processes | Adhere to defined AI development procedures |
| Quality | Ensure AI systems meet requirements |
| Documentation | Record design decisions and testing |
| Competence | Maintain required skills |
| Risk awareness | Identify and escalate AI risks |
Customer Responsibilities
| Responsibility | Description |
|---|---|
| Due diligence | Select appropriate AI providers |
| Appropriate use | Use AI within intended parameters |
| Training | Ensure users understand AI limitations |
| Oversight | Maintain human control where needed |
| Feedback | Report issues to providers |
Partner Responsibilities
| Responsibility | Description |
|---|---|
| Quality | Deliver services meeting AI provider requirements |
| Security | Protect data and systems |
| Compliance | Meet contractual and regulatory obligations |
| Communication | Report issues affecting AI systems |
EU AI Act Role Alignment
ISO 42001 roles map to EU AI Act terminology:
| ISO 42001 Role | EU AI Act Equivalent |
|---|---|
| AI Provider | Provider |
| AI Producer (Deployer) | Deployer |
| AI Customer | User |
| AI Partner | Various (importer, distributor, etc.) |
Understanding this alignment helps organizations prepare for EU AI Act compliance through ISO 42001 certification.
Practical Implications
Certification Scope Definition
Your roles directly inform your certification scope statement:
Example scope statements:
AI Provider + Producer:
"The AIMS covers the development, provision, and support of [Product Name] AI systems, including design, data management, model development, deployment, and customer support."
Internal Producer only:
"The AIMS covers the development and operation of internal AI systems supporting [business functions], including data management, model development, and deployment."
Customer with some development:
"The AIMS covers the governance of AI systems procured from third parties and the internal development of AI-powered features for [Product Name]."
Resource Allocation
Role complexity affects resource needs:
| Role Profile | Typical Effort |
|---|---|
| Provider + Producer | Higher (full scope) |
| Producer only | Medium |
| Customer + some development | Medium |
| Customer only | Lower (may not need certification) |
Need help determining your AI roles and certification scope? Talk to our team
