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AI Governance

ISO 42001: Is AI Management System Certification Worth It?

Joe Braidwood
Joe Braidwood
Co-founder & CEO
· December 2025 · 8 min read

The question I hear most often: "Should we get ISO 42001 certified?" It’s a fair question. The standard is new, certification isn’t cheap, and the AI governance landscape is shifting fast. Here’s my honest take on when certification makes sense—and when it doesn’t.

What ISO 42001 Actually Certifies

First, let’s clear up a common misconception. ISO 42001 doesn’t certify that your AI is safe, unbiased, or reliable. It certifies that you have a management system for AI—processes, governance structures, and documented controls for developing and deploying AI responsibly.

This distinction matters. An ISO 42001 certificate says: "This organization has implemented systematic processes for managing AI risk." It doesn’t say: "This organization’s AI systems won’t cause harm."

The standard covers critical governance elements:

  • AI policy and objectives aligned with organizational strategy
  • Risk assessment processes for AI-specific risks
  • Data governance for training and operational data
  • Development lifecycle controls from design through deployment
  • Monitoring and incident response for AI systems

Who’s Getting Certified and Why

Early adopters of ISO 42001 certification fall into predictable categories. Enterprise AI vendors—particularly those selling into regulated industries—see certification as a competitive differentiator. Healthcare AI companies, financial services providers, and infrastructure platforms are leading the charge.

Their motivations are practical:

  • Customer requirements: Large enterprises increasingly ask for AI governance evidence during procurement
  • Regulatory alignment: ISO 42001 maps well to EU AI Act requirements, providing a head start on compliance
  • Market positioning: First-mover advantage in demonstrating AI governance maturity
  • Internal discipline: The certification process forces systematic thinking about AI risk

I’ve also seen healthcare organizations pursuing certification—not AI vendors, but the health systems themselves. They’re building internal AI capabilities and want governance frameworks before deployment, not after.

The Real Cost of Certification

Let’s talk numbers. ISO 42001 certification isn’t a casual investment:

Cost Category Typical Range Notes
Implementation Consulting €30,000–€80,000 Gap analysis, documentation, training
Certification Audit €10,000–€30,000 Stage 1 + Stage 2 audits
Internal Resources 6–12 months FTE Project management, documentation
Annual Surveillance €5,000–€15,000/year Ongoing audit and maintenance
Recertification (Year 3) €8,000–€20,000 Full recertification audit

For a mid-sized AI vendor, you’re looking at €50,000–€100,000 in the first year, plus ongoing maintenance costs. These figures vary significantly based on organization size, existing certifications, and consulting approach—smaller organizations may pay less, while complex enterprises often pay more. That’s before accounting for the operational overhead of maintaining the management system.

Organizations with existing ISO certifications (27001, 9001) have an advantage. The management system structures are similar, reducing implementation effort by 30–40%.

ISO 42001 vs. SOC 2 for AI Governance

SOC 2 remains the de facto standard for enterprise software procurement. So how does ISO 42001 compare?

They’re genuinely complementary. SOC 2 covers IT security controls—access management, encryption, change control, incident response. It’s essential infrastructure, but it wasn’t designed for AI-specific risks.

ISO 42001 addresses what SOC 2 misses:

  • Model governance: Version control, testing, and validation of AI models
  • Bias and fairness: Systematic assessment of AI outputs across populations
  • Explainability: Documentation of how AI decisions are made
  • Human oversight: Governance structures for AI decision-making

For healthcare AI vendors, I’d argue you need both. SOC 2 satisfies security requirements. ISO 42001 demonstrates AI-specific governance. Neither alone is sufficient.

The "Certification Theater" Risk

Here’s my concern with any certification: it can become a box-checking exercise. Organizations implement the minimum required documentation, pass their audit, and display the certificate—without meaningfully changing how they develop or deploy AI.

ISO 42001 is particularly vulnerable to this. The standard is new. Auditors are still building expertise. And the requirements are process-focused, not outcome-focused. You can have impeccable documentation and still deploy AI systems that cause harm.

The uncomfortable truth: A certificate proves you have processes. It doesn’t prove those processes work. The gap between "documented control" and "operational evidence" is where real risk lives.

I’ve seen organizations with SOC 2 Type II attestations suffer major security incidents. The processes were documented. The controls existed on paper. But they weren’t operating effectively in practice.

When Certification Makes Sense

Certification is worth pursuing when:

  • Enterprise customers require it — Some RFPs now explicitly ask for ISO 42001 or equivalent AI governance certification
  • You’re selling into the EU — ISO 42001 aligns with EU AI Act requirements and may become a presumption of conformity
  • You need external validation — For some organizations, third-party certification carries weight that internal governance can’t match
  • You’re building governance from scratch — The certification process provides a structured framework when you have nothing in place

When Internal Governance Suffices

Certification may not be necessary when:

  • Your customers don’t require it — If your procurement conversations focus on SOC 2 and HIPAA, ISO 42001 may not move the needle
  • You have mature internal governance — If you’re already implementing NIST AI RMF controls with operational evidence, certification may just be paperwork
  • Resources are constrained — The €50K+ investment might deliver more value in actual AI safety improvements than in certification

Many organizations can achieve equivalent AI governance by implementing the ISO 42001 framework internally without pursuing certification. You get the structured thinking without the audit overhead.

The GLACIS Perspective: Certification + Runtime Evidence

My view: certification and runtime evidence are both necessary, but neither is sufficient alone.

ISO 42001 proves you have governance processes. But processes can fail. What healthcare organizations increasingly demand is evidence that controls actually executed for specific AI inferences. Not "we have a bias testing process," but "here’s proof bias testing ran for this model version."

This is the gap we see repeatedly: organizations with impressive certifications that can’t demonstrate operational evidence for their AI systems. When something goes wrong, they have documentation showing what should have happened—but no proof of what actually did.

The complete picture combines:

  • Certification — Third-party validation of governance processes
  • Runtime evidence — Continuous proof that controls execute in production
  • Third-party verifiability — Evidence that can be independently validated, not just internal logs

If you’re pursuing ISO 42001 certification, consider how you’ll bridge this gap. The certificate opens doors. The operational evidence is what builds lasting trust.

For a deeper exploration of what AI-specific evidence looks like, read our white paper on The Proof Gap.

Pango waving

Beyond the Certificate

Our white paper "The Proof Gap in Healthcare AI" explores the difference between documented controls and operational evidence—and why healthcare organizations are demanding both.

Read the White Paper