How to Conduct an ISO 42001 Gap Analysis: Step-by-Step Guide

How to Conduct an ISO 42001 Gap Analysis: Step-by-Step Guide

Identify Your AI Governance Gaps and Prepare for Certification with Confidence

Introduction

For organizations planning to adopt the ISO 42001 AI Management System standard, the most critical first step is understanding how far their current structure aligns with the standard's requirements.

This is precisely where Gap Analysis comes in.
It helps you assess your current AI governance practices against ISO 42001 and outlines the improvements needed for full compliance.

In this article, we’ll walk you through what an ISO 42001 Gap Analysis is, how to conduct one in six steps, and how to interpret the results to drive real transformation.

What Is an ISO 42001 Gap Analysis?

An ISO 42001 Gap Analysis is a structured assessment that compares your organization's existing AI-related processes with the clauses and controls outlined in the ISO 42001 standard.

Benefits:

• Identify misalignments and compliance gaps

• Gain visibility into strengths and weaknesses

• Build a targeted and measurable roadmap for ISO 42001 readiness

In short, a Gap Analysis answers the questions:
“Where are we today?” and “Where do we need to be?”

How to Perform an ISO 42001 Gap Analysis (6 Key Steps)

1. Define the Scope and Prepare the Team

Before starting the analysis:

• Define which departments and processes are in scope (not just IT—include legal, HR, risk, etc.)

• List all current AI systems and their business use cases

• Assign a responsible internal team or engage an external consultant

⚠️ Excluding critical processes from the scope can result in serious risks during future audits.

2. Review ISO 42001 Requirements

Use the ISO 42001 clauses as the foundation of your analysis. Key areas include:

• Organizational context and risk-based thinking

• Policies, roles, and governance structure

• Data and algorithm security

• Ethical principles, transparency, and human oversight

• Auditing, monitoring, and continuous improvement

Build a structured checklist based on these sections to ensure thorough coverage.

3. Assess Current Practices

For each ISO 42001 clause, assess your current implementation:

• Is the requirement currently met?

• If yes, is it documented and sustainable?

• Or is it ad-hoc, informal, or missing altogether?

Use a standardized classification system:

StatusMeaning✅ Fully CompliantRequirement is fully addressed and documented⚠️ Partially CompliantSome practices exist, but are incomplete or undocumented❌ Not CompliantNo existing practice or documentation

4. Collect Evidence

Every compliance status must be backed by evidence:

• Policies and procedures

• Training and awareness materials

• Risk assessment reports

• AI system user guides

• Feedback and audit logs

📌 Remember: A Gap Analysis is only as strong as the documentation supporting it.

5. Identify Gaps and Prioritize Actions

Once assessment is complete:

• List all non-compliant areas

• Prioritize gaps based on business risk and criticality (e.g., High / Medium / Low)

• Define corrective actions and assign responsible owners

This effectively becomes your ISO 42001 Remediation Plan.

6. Reporting and Executive Presentation

Create a clear and visual report to communicate findings to leadership:

Your Gap Analysis Report should include:

• Overall compliance rate (e.g., “Current status: 45% compliant”)

• List of critical gaps

• Recommended actions and owners

• Target dates for resolution

• Monitoring and follow-up methods

This report serves as the foundation for your ISO 42001 implementation roadmap.

When Should You Conduct a Gap Analysis?

You should conduct an ISO 42001 Gap Analysis if:

• You’re planning a new AI-related project

• You aim to achieve ISO 42001 certification

• You need to assess readiness for compliance with AI regulations

• You want to evaluate AI ethics, security, and risk posture

✅ It’s essential to perform a Gap Analysis before any ISO 42001 implementation or audit.

Conclusion

The ISO 42001 Gap Analysis is not just an audit—it’s a strategic tool that helps you measure your organization’s readiness for ethical, secure, and sustainable AI adoption.

With this analysis:

• You identify and visualize compliance gaps

• Build a targeted improvement roadmap

• Prepare confidently for certification and audits

At Technoserve, we offer expert-led ISO 42001 Gap Analysis services tailored for organizations in the UK, Europe, and beyond.

✅ We handle the process end-to-end—from assessment to reporting and executive briefings.

👉 Book your free initial consultation today and take the first step toward building a trustworthy AI governance system.