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ISO/IEC 42001 guide

ISO 42001 AI impact assessment: how to run it under clause 6.1.4, with ISO/IEC 42005

Clause by clause: ISO 42001 AI Impact Assessment: Examine Who May Be Affected →

What clause 6.1.4 of ISO/IEC 42001 requires, where ISO/IEC 42005 guidance fits, a six-step method, a worked example for an AI hiring tool, the record auditors expect and when the assessment must be repeated.

  • Updated September 2026
  • 8-minute read
  • Part of the ISO/IEC 42001 hub

Key points

  • ISO/IEC 42001 requires an AI system impact assessment in clause 6.1.4: a defined process that works out what each AI system's deployment, intended use and foreseeable misuse could mean for individuals, groups and society.
  • The result has to be documented and must feed into the AI risk assessment, so the two registers should visibly agree.
  • Clause 8.4 makes the assessment a living record: it is repeated at planned intervals and whenever a significant change is proposed or happens.
  • ISO/IEC 42005:2025 is guidance on how to carry out the assessment. Auditors certify against ISO/IEC 42001, not against ISO/IEC 42005.

What is an AI system impact assessment under ISO 42001?

An ISO 42001 AI impact assessment looks outward. Where the AI risk assessment asks what could help or hinder the organisation's AI objectives, the impact assessment asks what a particular system could do to the people it touches and to society more widely: the applicant screened out, or the patient given the wrong priority.

Clause 6.1.4 of ISO/IEC 42001:2023 requires you to define a process for assessing those potential consequences, whether they arise from developing, providing or using the system. For each system, the assessment covers its deployment, its intended use and the misuse you can reasonably foresee. It must take account of the technical and societal setting in which the system runs and the jurisdictions where it is used. The outcome is documented, and the standard requires the results to be considered in the AI risk assessment of clause 6.1.2.

The standard defines it as a formal, documented process in which impacts are identified, evaluated and addressed; an assessment that never decides what to do about an impact falls short.

Where ISO/IEC 42005 fits

ISO/IEC 42005:2025, titled "AI system impact assessment", was published in May 2025 as its first edition. It is a guidance document for organisations that carry out these assessments. It sits beside ISO/IEC 42001 in the same way that ISO/IEC 23894 sits beside the risk clauses: it helps you design and run the method, but nobody is certified to it.

So the certification body tests your process against clause 6.1.4 and the Annex A controls you selected, not against ISO/IEC 42005. The risk side of the pair, including how ISO/IEC 23894 is used, is covered in our AI risk assessment and treatment guide.

SourceWhat it asksEvidence an auditor expects
Clause 6.1.4 AI system impact assessmentA defined process; consequences of deployment, intended use and foreseeable misuse for individuals, groups and societies; technical and societal context and jurisdictions considered; results documented and fed into 6.1.2An approved procedure and one completed assessment per system in scope
Clause 8.4 AI system impact assessmentRepeat the assessment at planned intervals and when significant changes are proposed or occur; retain the resultsA review schedule, dated reassessments and change records that trigger them
A.5.2 and A.5.3An impact assessment process, and documentation of the assessmentsVersion-controlled assessments with owners and approval
A.5.4 and A.5.5Assessing impacts on individuals or groups of individuals, and societal impactsBoth levels addressed in each assessment, not only the individual one

The full set of 38 reference controls, including the other Annex A groups that touch this work, is explained in our Annex A guide.

How to run the assessment, step by step

ISO/IEC 42001 leaves the method to you. The sequence below is Sterling's recommended approach; it meets the clause and keeps each assessment to a workshop or two rather than a research project.

1. Describe the system and its setting

Record what the system does, its owner, your role (developer, provider or user), the decisions it informs or makes and the degree of human review. Name the jurisdictions where its outputs are used. The inventory built during scoping is the starting point.

2. Identify who is affected

List the people inside and outside the organisation whose lives the outputs can reach: direct users, the individuals the system decides about, groups that could be treated differently, and society more broadly where scale or public trust is involved.

3. Consider use and foreseeable misuse

Work through the intended use, then predictable misuse: advice treated as a final decision, or the system applied to a population it was never tested on.

4. Evaluate each consequence

For each potential consequence, record its severity, how many people it could reach, whether it can be reversed, and how likely it is. Sterling's recommended practice is to write short descriptions for each level so that two assessors reach the same answer.

5. Decide what addresses it

Agree a measure for each significant consequence: human review, a data change, a restriction on use, clearer information, or not deploying.

6. Feed the risk assessment, then approve

Carry each significant impact into the AI risk register, where it is treated alongside the organisation's own risks, and have the assessment approved and dated.

A worked example: AI screening of job applications

A mid-sized firm uses a third-party tool that ranks applicants for customer-service roles. The firm is a user of the system, and the vendor supplies the model. Five lines from its assessment show the structure; they are illustrative, not a template to copy.

Who is affectedPotential consequenceUse or misuseEvaluationMeasureInto the risk register
Applicants from under-represented groupsRanked lower because historic hiring data carries biasIntended useHigh severity, many people, hard to detectVendor's bias testing reviewed; quarterly check of shortlist make-upYes, with an owner in HR
All applicantsRejected with no human involvementForeseeable misuse: recruiters rely on the rank aloneHigh severity, reversible only if detectedNo rejection without a recruiter's review, logged in the systemYes
Applicants with disabilitiesVideo or timed tests disadvantage themIntended useHigh severity for the individualAlternative route on request, stated in the noticeYes
Society and the local labour marketSame tool used by many employers repeats the same exclusionsScale effectLow control, recorded for awarenessRaised with the vendor through the supplier reviewMonitored only

Because the model belongs to a vendor, much of the evidence comes from the vendor's documentation, agreed and checked under the supplier controls of Annex A group A.10.

The record, and when to repeat it

A useful record holds the system description, the affected parties, each consequence with its evaluation, the decided measures, the link to the risk register entries, the approver and the date. The documentation guide sets out how this fits with the rest of the AIMS records.

Clause 8.4 requires reassessment at planned intervals and whenever a significant change is proposed or takes place. Sterling's recommended triggers include a new model version, new training data, a new population or country of use, a change from advisory to automated decisions, a serious complaint or incident, and a vendor's change to a third-party model. Build them into your change process.

Where the same system also falls under privacy or AI regulation, share the inputs rather than running three unconnected exercises. Under GDPR a data protection impact assessment may be required, and the EU AI Act requires certain deployers, including public bodies and private entities providing public services, to assess fundamental-rights impact before first use. An ISO/IEC 42001 assessment can supply evidence to both but does not replace either; our guide on ISO/IEC 42001 and the EU AI Act explains where the certificate stops.

Mistakes that weaken the impact assessment

  • One assessment for the whole organisation. Clause 6.1.4 works system by system; a single generic document cannot show the consequences of a specific deployment.
  • Only individuals considered. Group and societal impacts are skipped, although Annex A treats them as a separate control.
  • No link to the risk register. Impacts are written up but never appear among the risks, so nothing is treated.
  • Vendor systems assumed out of reach. Using a third-party model does not remove the duty to assess its consequences in your own setting.
  • Written once. The model has been retrained since the assessment was signed. Our internal audit guide shows how to test for this.

How Sterling builds the impact assessment

Assessments your system owners can explain to an auditor.

Sterling's expert and experienced AI governance consultants run the first assessments as workshops with the people who own, build and use each system, agree the evaluation levels with your team and link every significant impact to the risk register. With Design™ your team completes the assessments under Sterling's structure and review; with Drive™ Sterling consultants carry the agreed work alongside your system owners. The assessments, their triggers and the links to risks live in Effivity, included with the engagement, at no additional cost. We ensure successful certification for our clients; an independent, accredited certification body audits and decides, as Sterling does not certify.

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AI impact assessment: questions buyers ask

Is an AI system impact assessment mandatory for ISO 42001 certification?

Yes. Clause 6.1.4 requires a defined process and a documented assessment, and clause 8.4 requires it to be repeated, so a certification body will expect to see completed assessments for the systems in scope.

Do we have to follow ISO/IEC 42005 to be certified?

No. ISO/IEC 42005 is guidance, and the audit is against ISO/IEC 42001, though it is a sound basis for your method.

Do we need an impact assessment for AI tools we only use and did not build?

Yes, for the systems in your AIMS scope. The clause covers consequences of use as well as development and provision.

How often should an AI impact assessment be updated?

At the interval you plan, commonly once a year, and whenever a significant change is proposed or occurs. Record the review even when the conclusion stays the same.

Can our GDPR DPIA serve as the AI impact assessment?

Not on its own. A DPIA centres on personal data, while clause 6.1.4 also covers group and societal consequences; share inputs between the two.

Who should carry out the AI impact assessment?

The system owner leads, with those who build or configure the system, those who use its outputs, and legal or privacy colleagues.

ISO/IEC 42001 implementation

ISO/IEC 42001 requirements

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