SC-AI-004 · Governance

AI risk classification and use-case tiering

Low effortCovered by ISO 27001: New for AISatisfies 21 obligations in 11 policies

What it means

  • A simple, written method to sort every AI use case into tiers, typically low, medium and high risk.
  • The tier decides how much control applies: a low-risk internal summariser needs light checks; a credit-decision model needs full testing, independent validation and human oversight.
  • Criteria usually include: does it affect customers' money, rights or access to services; how autonomous is it; how much personal data; can errors be reversed; is it customer-facing.

Why it matters

  • RBI FREE-AI expects use cases classified as low, medium or high risk in the AI policy, with periodic review.
  • Tiering keeps effort proportionate. Without it, either everything gets heavy review (slow) or nothing does (risky).
  • Many other controls (red teaming frequency, human oversight, audit depth) are triggered by tier.

Checklist

  1. Write tiering criteria and a short scoring sheet (5 to 8 questions) in or alongside the AI policy.
  2. Give examples for each tier relevant to the business (for example: chatbot FAQ = low; collections prioritisation = medium; loan underwriting = high).
  3. Define what each tier requires: approvals, tests, validation, monitoring frequency, oversight.
  4. Classify every entry in SC-AI-003 AI system inventory and record the rationale.
  5. Re-tier when purpose, data or autonomy changes, and at least annually.
  6. Have the AI committee review all high-risk classifications.

Evidence examples

  • Approved tiering methodology (part of AI Policy v1.2, section on risk classification).
  • Completed scoring sheets for sampled AI systems with reviewer sign-off.
  • Inventory extract showing tier and last tiering date.
  • Committee minutes confirming high-risk classifications.

Common pitfalls

  • Tiering by technology ("it uses an LLM so it is high risk") instead of by impact on people and business.
  • Business owners self-classifying everything as low risk with no challenge.
  • Never re-tiering after a pilot becomes a production customer journey.

Satisfies

Standards crosswalk

Clause references only. Check the standard itself for the exact wording.

ISO/IEC 42001

  • 6.1.1 Actions to address risks and opportunities (risk criteria)
  • 6.1.2 AI risk assessment
  • A.5.2 AI system impact assessment process

ISO/IEC 27001

No direct equivalent

SOC 2

  • CC3.2

Key takeaways

  • Tiering makes AI governance proportionate and drives the depth of every other control.
  • New for AI, not covered by ISO 27001. Information classification (A.5.12) is a useful pattern to copy, but it classifies data, not AI use cases.
  • Classify by impact on customers and the business, and re-tier on change.

Find your gaps

Our free compliance gap assessment shows which of these controls you already run.

Start the gap assessment

Have us build it with you

Our AI Governance service implements controls like this one and produces the evidence auditors expect.

Explore AI Governance