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Learn · AI Governance

What Counts as an AI Incident

Two failure modes account for almost every AI incident process we are asked to review. One has logged nothing across a year and more of heavy AI use. The next logs every hallucination and has a register nobody reads. Both fail the same test, because neither can tell you what is actually going wrong.

The classification test, in one sentence. An event is an AI incident when model behaviour, AI-generated content, autonomous decisioning or agent tool use materially contributed to the outcome. Most such events are also ordinary IT, security or privacy incidents. The answer is to tag them as both, not to choose.

A.8.4ISO 42001 control on communicating AI incidents
CC7.3where SOC 2 turns an event into an incident
20+frameworks TCSA advises across

Plain-English explainer · ISO/IEC 42001:2023 · ISO/IEC 27001:2022 · TSC 2017 (rev. 2022) · NIST AI RMF 1.0 · OWASP Top 10 for LLM Applications 2026 · EU AI Act Article 73 (post-omnibus dates) · Last reviewed August 2026

An AI incident is an event in which model behaviour, AI-generated content, autonomous decisioning or agent tool use materially contributed to harm, to a loss of control, or to a failure to meet a commitment or an objective. The word doing the work is materially. If the same event would have happened in the same way with the AI component removed, it is an ordinary incident that happened near some AI. If the AI component changed whether it happened, how far it went, or how long it took to notice, it is an AI incident as well — and it is almost always as well, not instead. That dual classification is the practical heart of this page. A support assistant that pastes one customer’s data into another customer’s ticket is a confidentiality incident by impact and an AI incident by mechanism. Running it as only the first means the retrieval fault never surfaces across the other four assistants sharing that connector. Running it as only the second means nobody notifies the affected customer on the clock your contract requires.

The standards are less exotic on this than the discourse suggests, and it is worth being precise about what each one actually says. ISO/IEC 42001:2023 control A.8.4 — communication of incidents — requires a documented plan for communicating incidents to users of the AI system. The standard’s own implementation guidance in Annex B.8.4 expects that plan to cover what constitutes an AI incident, the notification timelines and the details to be reported. So the definition is guidance rather than clause text, the Annex A controls are reference controls applied through the Statement of Applicability rather than blanket obligations, and the drafting is entirely yours. ISO/IEC 27001:2022 control A.5.25 is a triage control: assessment of events and the decision on which are incidents. And the SOC 2 criterion CC7.3 does the same work in a single sentence, requiring that the entity evaluates security events to determine whether they could or have resulted in a failure to meet its objectives — the parenthetical in that criterion is where an event becomes a security incident at all. You already own the machinery. What you are missing is the AI-aware intake question, seven category definitions, a set of AI severity anchors slotted into the scale you already use, a written threshold, a notification matrix, and about a dozen extra fields on the record.

Key Takeaways

  • An event is an AI incident when model behaviour, AI-generated content, autonomous decisioning or agent tool use materially contributed to the outcome — the counterfactual test is whether removing the AI component would have changed whether it happened, how far it spread, or how long it went unnoticed.
  • Most AI incidents are also security, privacy or availability incidents. Tag both, run one record, and let the impact tags drive notification while the AI tags drive root cause and trending.
  • Six categories cover almost everything worth defining: unauthorised agent action, harmful or unsafe output, data leakage through prompts or outputs, agent malfunction, unintended change to systems or data, and model-behaviour regression — with governance or approval failure as the seventh, which is usually the root cause of one of the other six.
  • Not every caught hallucination is a ticket. The threshold that survives contact with an assessor is that an inaccuracy becomes an incident when it reached beyond the review loop, when it recurs as a systemic failure mode, or when it could plausibly have been high-impact — and everything below the line is aggregated and trended rather than discarded.
  • You almost never need a separate AI incident register. You need AI incidents to be identifiable, investigable, trendable and reportable inside the existing process, which in practice means a mandatory classification field rather than a second system nobody staffs at three in the morning.
  • An AI incident record needs about a dozen fields an ordinary one does not: model and version, the trigger, the assembled context, every tool call including denials, the identity the agent acted under, the actions and their side effects, and the human oversight status — captured at the time, because configuration and trace data both expire.
The classification question

Is this an AI incident, or just an incident?

Work the two columns independently. Ask whether the event is an incident under the definitions you already use, then ask separately whether an AI component materially contributed. The answers are not exclusive and the third column is where most of the argument in a triage call actually lives.

EventIT / security incident?AI incident?The reasoning
A phishing email steals an employee session cookie and the attacker reads their mailbox.YesNoNo AI component contributed to the event or its impact. Run it exactly as you always have. Having AI somewhere in the estate does not make every event an AI incident, and a taxonomy that says otherwise stops being informative within a quarter.
An employee pastes a signed customer contract into a personal chatbot account to summarise it.Yes — disclosure of confidential data to an unapproved processorYesThe AI tool is the disclosure channel, but the failure is an approval and awareness failure rather than a model-behaviour one. Tag both. The corrective action belongs to shadow-AI discovery and to the approved-tool path, not to the model.
A support assistant replies to a customer with a paragraph drawn from a different customer ticket.Yes — confidentialityYesRetrieval scope and model composition together produced the disclosure. The impact is a confidentiality incident. The mechanism is an AI one, and only the AI tags will tell you whether it recurs across other assistants sharing that connector.
A coding agent proposes a dependency with a known critical vulnerability. CI blocks the merge.NoNot on a single occurrenceThe control operated and nothing reached an environment. This is a near miss and belongs in the aggregate quality log. It becomes an incident if the pattern recurs, or if investigation shows the block held by luck rather than by design.
After a model version change, an agent begins closing tickets without the confirmation step it was designed to require.Yes — unauthorised change to recordsYesTwo AI categories at once: unauthorised agent action and model-behaviour regression. Without the version field on the record, the second one is invisible and you will fix the symptom.
Text embedded in a fetched web page causes an agent to call a tool outside its task.Yes — an attack succeeded against a systemYesAttacker-controlled content steering tool selection is the AI dimension, and it changes the remediation entirely: the answer is capability scoping and confirmation design, not user training.
The model provider has a two-hour API outage and the internal assistant is unavailable.Yes — supplier availabilityOnly if a governed AI system degraded unsafelyAn unavailable assistant is a supplier availability event. It becomes an AI incident when the outage caused a fallback path to behave in a way nobody assessed — stale cached answers served as current, or a queue of agent actions replaying on recovery.
A summarisation feature states a wrong revenue figure in an internal draft. The analyst catches it.NoNo, as a single occurrenceThe oversight step operated and that is the system working as designed. Record it as a quality signal. It becomes an incident if the same error recurs, if it reaches a decision, or if you find the review step was not actually being performed.
A periodic review of a screening tool finds a consistent pattern of disadvantage against one group.NoYesThere is no timestamped trigger and no alert fired, but material harm is attributable to system behaviour. Open the record dated to detection, with the analysis itself as the trigger artefact and the affected population as the impact.
An agent holding cloud credentials deletes a non-production storage bucket during a cleanup task.Yes — unauthorised changeYesAutonomy contributed directly to the outcome. Severity follows reversibility rather than intent: a restorable bucket is a low-severity incident and a real one, because the same authority reaches production.

The intake procedure, in six lines

Everything on this page is downstream of six questions. Put them in the runbook in this order, so the responder at eleven at night can follow them without reading the rest.

  • 01 Does the AI contribution field say contributed or primary cause? If it says no, run the ordinary process and stop here.
  • 02 Which of the seven categories applies? More than one is normal and both get tagged.
  • 03 Did it escape the loop, does it recur as the same failure mode, or could it plausibly have been high-impact? Any one of the three makes it an incident rather than a quality signal.
  • 04 What severity, read off the anchors — recipient, reversibility, data class, whether a decision path was affected?
  • 05 Has any statutory or contractual clock started? Ask this before the severity meeting sits, because the clocks run from awareness and not from classification.
  • 06 Which run-record fields have to be captured now, before they expire — model version, tool-call sequence, identity, action identifiers, guardrail configuration as it stood at the time?

Two habits make this table unnecessary within a quarter. The first is putting the question into intake rather than into a policy: a required field on every incident record asking whether an AI system contributed, with three options — no, contributed, primary cause — collects the data whether or not the person on call has read the taxonomy. The second is accepting that the classification will sometimes be wrong on first pass and building a review step into closure rather than into triage. An assessor is not looking for a process that never misclassifies. They are looking for one that records the decision, applies stated criteria, and corrects itself.

One boundary worth settling early. A tool that only drafts and a tool that acts are not the same governance object, and the classification threshold moves sharply once tool invocation enters the picture — the distinction is worked through in when a tool becomes an AI agent. If your estate is entirely drafting assistants, most of what follows still applies but the unauthorised-action and unintended-change categories will stay empty, and that is a legitimate finding rather than a gap.

Severity

The anchors that make an AI severity call

These anchors slot into the severity scale your organisation already runs. They do not replace it, and inventing a parallel AI scale is the mistake that makes AI incidents incomparable with everything else on the board pack. What the AI column adds is the set of facts that decide the level for an AI event, which are not the facts a network or endpoint incident turns on: who or what received the output, whether an action reached a system and can be undone, whether a human decision depended on it, and whether a clock has started.

LevelAnchor definitionAI-specific anchorsResponse and escalation
CriticalIrreversible effect outside the organisation, a regulated decision affected, or an autonomous action that reached production and destroyed or corrupted data.The agent wrote to or sent to external parties and the action cannot be retracted. An autonomous action executed against a production system. Harmful output reaching a protected group or a regulated domain. A statutory reporting clock has started.Suspend the agent immediately rather than after the meeting. Executive and legal engaged within the hour. Notification assessment the same day, with the clock recorded against the awareness timestamp, not the classification timestamp.
HighExternal recipient, but reversible or retractable, or an internal effect on a decision that a person relied on.Cross-tenant disclosure caught after delivery. An unauthorised tool call that succeeded. A model-behaviour regression sitting on a path where a human decision depends on the output. Bulk modification of records with identifiers recoverable.Contain within the shift. AI system owner and the impact-assessment owner both on the record. Retraction attempted and the attempt recorded whether or not it worked. Customer communication drafted before it is asked for.
MediumInternal only and contained, with the control chain intact and no external effect.An unauthorised tool call denied at the gateway on a tool the agent has never needed. A regression inside a decision path where human review demonstrably still operated. A spend or loop event stopped by a limit.Normal queue with a named owner and a fixed close date. The corrective action goes to capability scoping or to the evaluation gate, not to user training.
LowNo impact and the control operated as designed. Recorded because the causal chain is worth having.A near miss on a high-consequence path. A denial on a tool adjacent to the approved set. A single caught inaccuracy on a path where inaccuracy would have mattered.Recorded with impact stated as none, closed quickly, and counted in trending. These are the entries that make a short register credible rather than suspicious.

Two anchors are worth arguing about in advance, because they are where a triage call stalls. Reversibility outranks intent and outranks volume. An agent that modified four thousand records recoverably is a lower severity than one that sent three emails, because the emails cannot be unsent. That ordering feels wrong the first time a team applies it and correct every time afterwards. Unauthorised action is severity-bearing even at zero impact. An agent that called a tool it was never approved for and caused no harm still sits at Medium rather than at Low, because the authority boundary is the control you are claiming operates, and it did not. Reserve Low for events where the control worked.

The threshold

Not every hallucination is a ticket

The failure mode here is symmetrical and both halves are common. Log everything and the register becomes a stream nobody triages, which is functionally the same as logging nothing except that it costs more. Log nothing and you have no population, no trend, and nothing to show an assessor. The way through is two tiers with a written line between them, and the discipline that what falls below the line is aggregated rather than discarded.

SignalDefault dispositionWhat moves it up to an incident
One wrong fact in a draft, caught by the person who asked for itQuality log, aggregated. Not an incident.Same wrong fact three times in a week, the draft went out, or you discover the reviewer had stopped reading and the catch was chance.
A refusal that blocked a legitimate taskQuality log. It is a usability defect.Refusals concentrate on one group of users or one topic, which turns a defect into a fairness question worth a record of its own.
An agent action denied at the tool gatewayAggregate. Denials are the control working.A rising denial rate, denials on a tool the agent has never needed, or a denial pattern consistent with content-borne instructions rather than user intent.
An output that reached a customer, a regulator or a public channelIncident. Always.Nothing needs to move it up. The question at this point is severity and notification, not whether to open a record.
An evaluation regression inside your stated toleranceMonitoring record, reported in the periodic review.It crosses the threshold, it persists across two runs, or it lands on a metric that a human decision depends on.
A spend or volume spike with no business explanationIncident, provisionally, until the run is explained.It stays an incident if the cause was agent behaviour rather than legitimate demand — and this is the one place where opening early costs nothing and closing late costs a lot.
A near miss where the control held, but only justIncident, with impact recorded as none.Near misses are the single most valuable entries in the register, because they carry the whole causal chain without the harm. A register with no near misses in it is a register nobody trusts.

Three questions decide the line, and they are worth writing into the procedure verbatim because they are what a triage call needs at eleven at night. Did it escape the loop? An output that reached a customer, a regulator, a public channel or an automated downstream system is an incident regardless of how minor it looks, because you no longer control its consequences. Is it recurring or systemic? A single wrong answer is an occurrence, but the same failure mode three times is a defect in the system and belongs on the record where it can be trended. Could it plausibly have been high-impact? Near misses on high-consequence paths — an agent that nearly wrote to production, an approval that nearly went through unread — carry the whole causal chain without the harm, and they are the most valuable entries in any register.

Below the line, the aggregate matters more than any single entry. Feedback ratings, evaluation failures, override rates, refusal rates, denied tool calls and support escalations are all monitoring data, and they are what ISO/IEC 42001 Clause 9.1 has in mind when it asks what you monitor, measure, analyse and evaluate. They also answer the question a buyer or an assessor asks about a short incident register, which is never really why is this list short — it is what would you have seen if something had been going wrong.

The clocks

Who has to be told, and by when

Notification is the hinge the whole classification design turns on, and the single structural fact to absorb is this: every clock below runs from awareness, not from classification. You cannot buy time by deferring the severity call. That is why the intake question about a statutory clock has to sit ahead of the severity meeting, and why an incident procedure with a weekly triage cadence cannot serve a two-day obligation no matter how good the people running it are.

ObligationNotify whomClockRuns fromTriggered when
EU AI Act Article 73The market surveillance authority of the Member State where the incident occurred15 days, 10 days where a person has died, 2 days for a widespread infringement or a serious incident affecting critical infrastructureAwareness — specifically once a causal link between the system and the incident, or its reasonable likelihood, is establishedYou are the provider of a high-risk AI system placed on the Union market, and a serious incident as defined at Article 3, point (49) has occurred. Subject to the Digital Omnibus deferral: 2 December 2027 for stand-alone Annex III systems, 2 August 2028 for Annex I embedded AI.
EU AI Act Article 55(1)(c)The AI Office and, as appropriate, national competent authoritiesWithout undue delayBecoming awareYou are the provider of a general-purpose AI model with systemic risk. This obligation is not deferred — GPAI model obligations have applied since 2 August 2025.
GDPR Article 33The lead supervisory authority72 hoursAwarenessA personal data breach, unless it is unlikely to result in a risk to the rights and freedoms of natural persons. An AI incident that disclosed personal data is a personal data breach, and the AI mechanism does not change the clock.
GDPR Article 34The affected data subjectsWithout undue delayAwarenessThe breach is likely to result in a high risk to the rights and freedoms of natural persons.
DPDP Act 2023 (India)The Data Protection Board of India and each affected Data PrincipalIn the form and manner prescribed by the RulesBecoming aware of the breachYou are a Data Fiduciary and a personal data breach has occurred. Read the operative timing off the current Rules rather than off a summary, including this one.
ContractualEnterprise customers, and often their own regulators through themCommonly 24 to 72 hours as negotiatedAwareness in some contracts, declaration of an incident in othersWhenever the contract says so — and which of those two triggers you signed up to is a clause worth reading before signature, because declaration-based wording gives you a triage window and awareness-based wording does not.

The AI Act row carries a date qualification that most comparisons written before August 2026 get wrong, so it is worth stating plainly. The Act is Regulation (EU) 2024/1689. It was amended by the Digital Omnibus on AI, Regulation (EU) 2026/1744, published in the Official Journal on 24 July 2026 and in force from 27 July 2026, which deferred the stand-alone Annex III high-risk obligations to 2 December 2027 and Annex I embedded high-risk AI to 2 August 2028. For most organisations Article 73 is therefore a clock to design for rather than one already running — the exception being providers of general-purpose AI models with systemic risk, whose serious-incident duty has applied since 2 August 2025. The full post-omnibus timeline, and how it interacts with an ISO/IEC 42001 management system, is set out in ISO 42001 versus the EU AI Act.

Two practical consequences follow from putting these in one table. The shortest clock that could apply sets your triage design, not the most likely one. If any obligation in your matrix runs in days, your intake needs a path that reaches legal and privacy the same day, whatever the severity call eventually says. Assessed-as-not-notifiable is a decision that needs a record. The half of the population teams forget to keep is the events they looked at and correctly decided not to report. Without those records, an assessor cannot distinguish a considered judgement from an omission, and the difference is the whole finding.

The register question

Do you need a separate AI register?

Almost always, no. The test is not where the records live but whether four things are possible: AI incidents can be identified, investigated, trended and reported within the process you already run. If they can, a second register adds a coordination failure at exactly the moment you can least afford one. If they cannot, the fix is nearly always a field and a workflow rather than a system.

Identified means a mandatory classification field at intake and a stored query that returns the AI population without anyone assembling it by hand. Investigated means the extra record fields in the next section are captured, and that the AI system owner is on the escalation path rather than being consulted three days later. Trended means you can cut the data by system, category, model version, tool and detection source. Reported means the analysis reaches a management review with decisions attached, and that the communication plan A.8.4 asks for gets exercised rather than merely maintained.

Three situations genuinely justify separation, and it is worth being honest about which one you are in. A statutory clock your general process cannot meet — where the EU AI Act will reach you as a provider of a high-risk system from 2 December 2027 under the post-omnibus timeline, Article 73 deadlines run from awareness, and a triage cadence built for a five-day service target cannot serve a two-day obligation. Providers of general-purpose AI models with systemic risk are the exception that is already live. A contractual scope that excludes non-security events — some security incident procedures are written narrowly enough that a fairness finding or a model regression has no home in them, in which case the honest move is to widen the procedure rather than to bolt on a second one. A genuinely separate product-quality function — a model behaviour tracker owned by an ML team is a reasonable thing to have, provided the governance register can see into it and the criteria for promotion between them are written down.

What decides this in an audit room is unglamorous. An ISO/IEC 42001 assessor will ask you to produce the AI incidents for the period. If the answer involves someone reading through a general incident queue and using judgement, you do not have an identifiable population, and the finding is against the process rather than against the tooling. A single mandatory field, applied from day one, is the difference between a five-minute export and a two-week reconstruction — and it is also the difference between trending that means something and a chart assembled once for a slide.

The same logic applies across the management systems. If you already run ISO/IEC 27001, the incident controls at A.5.24 through A.5.28 are the ones your AI events will be tested against for the security dimension, and the sensible design integrates rather than duplicates — the mechanics of running both are set out in integrating ISO 42001 with ISO 27001.

Worked example

One leak, nine tickets, two root causes

An illustrative composite, not a client. A B2B SaaS company running a customer-support assistant: it drafts and posts replies in the ticketing system, retrieves from a shared knowledge base through a connector, and holds a tool that can close tickets. Read the dates, and read the sixth row twice — it is the one that only exists because the earlier rows were tagged consistently.

Trigger12 Feb 2026, 09:14A customer replies to a support ticket. The assistant drafts and posts a public reply that includes two sentences describing a different customer’s contractual terms, retrieved from the knowledge base through a connector scoped to a shared service account.
Detection12 Feb, 11:40The customer replies asking why the response describes another company’s contractual terms. Time-to-detect is two hours and twenty-six minutes, and the detection source is the affected party — the worst of the available sources, and the one that sets the tone of everything that follows.
Classification12 Feb, 12:20Logged once in the existing incident system. Primary tag: confidentiality. AI tags: data leakage through outputs, with governance failure noted as a candidate root cause. Severity set from recipient and data class, not from the fact that AI was involved.
Investigation12–17 FebThe run record shows the retrieval step returned four documents, one belonging to another tenant, because the connector inherited the service account’s entitlements and the retrieval filter asserted tenancy in the prompt rather than in the query. The model did exactly what the context supported.
Correction18 Feb – 3 MarTenancy moves into the retrieval query, the connector is re-scoped, and the assistant is put behind a human release step for external replies. The impact assessment for the assistant is reopened, because the original one assumed retrieval could only reach the requesting tenant.
Second signal9 MarTrending across the AI tags shows nine records in six days of the assistant closing tickets without the confirmation step. All nine post-date a provider model version change on 3 March. Individually each looked like a user complaint, but together they are a model-behaviour regression.
Governance outcome24 MarTwo corrective actions to the March management review: pin the model version and gate changes behind an evaluation run, and add a monitoring rule on confirmation-step bypass rate. Both close with named owners and dates.

The model was not the fault in either case. On 12 February the fault was an authorisation boundary implemented in a prompt instead of in a query — the retrieval layer was told to respect tenancy rather than being unable to violate it. That is a permission-inheritance failure of exactly the kind connectors produce, and the same pattern would have leaked without any model involved. On 9 March the fault was a version change consumed silently, with no evaluation gate between the provider release and production behaviour.

What made the second detection possible was the first record being tagged properly. Nine customer complaints spread across three support agents look like nine complaints. Nine records carrying the same AI system identifier, the same category and a model version that changed on 3 March look like one regression with a date. That is the entire argument for the record schema in the next section, and it is why the fields have to be captured at the time rather than reconstructed: by 24 March the provider had moved on, and the only proof of which version ran on 9 March was the field written by the intake form.

A single AI incident tells you about a system. A trend across consistently tagged AI incidents tells you about a change. Only the second one prevents anything.
— the reason the classification field is mandatory at intake

Two of the corrective actions above are worth naming as patterns rather than fixes. Moving tenancy from the prompt into the query is the general form of not relying on instructions to enforce a boundary. Pinning a model version behind an evaluation gate is the general form of treating a provider release as a change subject to your change process, not as weather.

Evidence

What the assessor actually requests

Whether the examination is an ISO/IEC 42001 certification audit conducted by an accredited certification body, a SOC 2 examination performed by a licensed CPA firm, or a customer security review, the requests take the same shape and they begin in the same place. Not with a screenshot — with a population, because a sample drawn from an incomplete list proves nothing about the list it came from.

The requestWhat satisfies itWhat gets rejected
The complete population of AI incidents for the periodA filtered export from the incident system using a stored, repeatable query on the AI classification field, with the filter, date range and record count visible, produced before any sample is drawn.A list assembled by hand for the assessment. A tracker separate from the operational system, which raises the question of what the operational system contains instead.
Evidence that the population is completeReconciliation against independent sources: alerting and monitoring output, the concerns and complaints channel, evaluation-run results, spend anomalies, and the AI system inventory, with differences explained.A register with three entries and no reconciliation. Any gap between an obvious operational event — a public apology, a customer credit, a rolled-back release — and a corresponding record.
The classification decision for a sample of eventsFor each selection, the recorded decision, the criteria applied, who decided, and when — including events assessed and correctly classified as not an AI incident, which is the half teams forget to keep.Classification applied retrospectively at close. A decision with no named decider. A criteria document that does not match how the records were actually tagged.
The run record behind one incident, end to endModel and version, trigger, assembled context, the full tool-call sequence with parameters and denials, the identity used, and the actions with their identifiers — retained for the full period, not just the last thirty days.Application logs that show a request and a response and nothing between. Trace data expired because retention was shorter than the assessment window and nobody checked.
Evidence that human oversight operatedThe approval record with the reviewer, the timestamp, what was presented, and elapsed time — plus, for the sample as a whole, evidence that reviewers sometimes rejected or amended what they were shown.A hundred approvals, none rejected, with a median elapsed time of two seconds. That is a rubber stamp and it will be named as one.
Evidence that communication happened as the plan requiresThe notification itself with its date, mapped to the plan’s committed timeline, the decision record for events assessed as not notifiable, and any regulatory submission with its acknowledgement.A plan with notification timelines that no incident record demonstrates. A customer told informally by an account manager with nothing in the record.
Evidence that trending fed somethingThe periodic analysis, the risk or impact assessment it updated, the monitoring threshold or guardrail it changed, and the management review minute where it was discussed and a decision taken.A chart with no consequence. Corrective actions raised and left open across two review cycles, which reads as a process that records problems rather than one that resolves them.

Selection sizes follow the population and the control frequency, not the subject matter. For a SOC 2 examination the service auditor draws from the incident population using the firm’s own sampling guidance rather than a number published anywhere. For an event-driven population in the low tens, expect the whole population to be examined rather than a sample, and for a population below roughly twenty-five items expect every record to be read. That has a consequence teams consistently underestimate: at small populations there is no averaging out. One record missing a model version or a tool-call trace is a defect rate the auditor cannot dismiss, where the same omission in a population of eight hundred access grants would be immaterial. Under an ISO/IEC 42001 certification audit the mechanism differs — the auditor samples across systems, sites and processes against an audit plan rather than to a statistical basis — but the exposure is identical, because a small population is read in full either way.

Where the AI incident population is genuinely nil for the period, the test does not disappear. It moves entirely onto completeness. Nobody accepts an empty register on its own. The auditor will instead examine the aggregate signals sitting below your threshold — the evaluation runs and their failures, the concerns channel, the escalation queue, denied tool calls, override rates, spend anomalies — to establish that nothing which should have produced a record failed to. This is the single strongest argument for building the below-the-line aggregation on day one rather than the day before fieldwork: a nil population with several hundred recorded signals underneath it is defensible, and a nil population with nothing underneath it is a finding waiting to be written.

The completeness problem is sharper here than anywhere else in an AI programme, and it is worth understanding why. Most control populations are large and mechanical — every merge, every joiner, every access grant — so completeness is a reconciliation exercise. An AI incident population is small and depends on human classification, so an assessor tests it from the outside in. They will read your evaluation results, your support escalations, your bug tracker, your status page and your customer credits, looking for an event that plainly should have produced a record and did not. One such gap does more damage than a badly written record, because it puts the whole population in question rather than a single entry.

A vocabulary note that saves time in fieldwork. What the auditor is establishing about anything you export is its completeness and accuracy, and for a SOC 2 examination the artefact class has a name — information produced by the entity, shortened to IPE. That is why they want the stored query, the filter, the date range and the record count visible rather than the result alone. For an ISO/IEC 42001 audit the vocabulary differs but the instinct is identical, and the auditor will also want to see the incident process running against its own documented criteria rather than against recollection.

One boundary, stated plainly because it is asked about often. ISO/IEC 42001 certificates are issued by accredited certification bodies and SOC 2 reports by licensed CPA firms. Tranquility Cybersecurity designs the classification criteria, builds the record schema, prepares the evidence and coordinates the examination — it does not certify, attest, audit or sign. Where a firm designs or operates a control, it cannot then be the party that examines it, which is the reason for the separation rather than a matter of preference.

From the other side of the table

What buyers push back on and the answer

These seven now appear in almost every enterprise security review of a vendor running AI in a customer-facing path. The difference between a good answer and a defensive one is specificity, and in most cases the specific answer is shorter.

“Your register shows four AI incidents in a year. That means you are not detecting them.”

A fair challenge and the right answer is not a bigger number. Show the threshold document that says what is logged as an incident and what is aggregated as a quality signal, then show the aggregate volumes underneath it — evaluation failures, near misses, denials at the tool gateway, user reports. Four incidents above a stated threshold, sitting on top of several hundred recorded signals below it, is a credible picture. Four incidents with nothing underneath is the one that should worry them, and it is worth naming that distinction yourself before they do.

“Send us your AI incident response plan.”

Usually they are testing whether AI events have a defined path, not asking for a separate document. The strongest answer is your existing incident procedure plus the AI annex: the classification criteria, the taxonomy, the extra record fields, the escalation path that brings in the AI system owner, and the communication plan. If you maintain a wholly separate plan, expect the follow-up about how the two interact at three in the morning. One process with an AI-aware intake almost always reviews better than two processes with a coordination problem between them.

“Will you notify us when the underlying model changes?”

Answer with the commitment you can actually hold, because this one turns into a contract clause. Most organisations cannot commit to notifying on every provider-side change, since providers do not always announce them at a useful granularity and some changes are not visible from outside. What you can commit to is notifying on changes you initiate that affect the service, on provider changes you become aware of that materially affect behaviour, and on any incident classified as a model-behaviour regression. Say which of those you are offering rather than agreeing to a general obligation you will breach quietly.

“Hallucinations are incidents. Why are they not in your register?”

Because a register that contains every wrong sentence stops being usable for exactly the purpose they care about. Explain the two-tier design: individual inaccuracies are aggregated as quality signals and trended. An inaccuracy becomes an incident when it reaches someone outside the review loop, when it recurs as a systemic failure mode, or when it could plausibly have been high-impact. Then show the trending, because the buyer question underneath this one is whether you would notice a pattern — and a threshold plus trend data answers that far better than a longer list.

“Who is on call for the agent at two in the morning?”

Answer with the same specificity you would for any production service: which conditions raise an alert, where it lands, who holds the rota, what response target you have committed to, and what the record shows for alerts that fired during the period. For agents there is a second half that buyers increasingly ask about and it is worth volunteering — what stops autonomously overnight without a human. A rate limit, a spend ceiling and a circuit breaker that suspends the agent on an anomaly are what make a two-person rota defensible instead of aspirational.

“What is your recovery time if you have to switch an agent off?”

Two distinct numbers and conflating them is the common mistake. Time to stop is how long from decision to the agent no longer acting, and for a well-designed system it should be seconds to minutes, tested rather than asserted. Time to restore service is how long until the business function resumes, which usually means a documented manual fallback and the people to run it. If the honest answer is that the manual process no longer exists because the agent absorbed it, say so and treat it as a resilience risk on the register rather than discovering it during the first suspension.

“Do your prompt logs contain our data, and who can read them?”

A legitimate question that deserves the schema rather than a reassurance. State what is captured by default — metadata, tool calls, identities, outcomes — what content capture applies to, the retention period for each tier, who holds access and under what approval, whether redaction runs on ingest, and where the logs are processed. If content capture is on for their tenant, tell them, because they will find out during their own incident and finding out then is far more expensive than being told now.

A closing observation about all seven. The buyer is not testing whether you have had incidents. They assume you have. They are testing whether you would know, whether you could tell them, and whether the answer would arrive in a form they can act on. A threshold document, a tagged register, a record schema and a trend chart answer all three questions at once, and they take a fortnight to build if you start before you need them.

Where to start

The first fortnight, in order

Nothing on this page requires a platform purchase and none of it needs to wait for a certification decision. Two of these run long and are the reason to start them in parallel rather than in sequence — the telemetry check and the inventory check both depend on engineering time you do not control. Every row names the artefact it produces and how that artefact gets tested later, because a step that produces nothing an assessor can read is a step you will repeat.

DayActionOwnerArtifact it producesHow it is evidenced later
Day 1–2Add the mandatory AI contribution field to the existing incident record type, with three options: no, contributed, primary cause.Incident process ownerThe field definition, plus a stored query that returns the AI population on demand.The five-minute export an assessor asks for, with the filter, date range and record count visible.
Day 3–5Write the definition, the seven categories, the severity anchors and the three threshold questions into the incident procedure. Two paragraphs each, no more.AI management system ownerA versioned, dated revision of the incident procedure with an AI annex.The criteria document the assessor compares against how the records were actually tagged.
Day 3–5Agree what sits below the line and where it aggregates, so nobody decides at eleven at night whether a wrong summary is a ticket.Incident process owner with the AI system ownersThe threshold document, with the aggregation destination named for each signal type.The aggregate volumes underneath a short register — the answer to the four-incidents challenge.
Day 5–10Confirm the run telemetry behind the record schema exists, and that its retention exceeds the reporting period plus the lag before anyone asks.Platform engineeringA log-store inventory with retention written beside each store, and an export configured wherever retention falls short.The run record behind one incident, end to end, produced for a month eleven months ago.
Day 5–10Check the AI system inventory is real and that every record can be joined to an assessed system by identifier.AI management system ownerThe inventory, with the identifier used in incident records as its primary key.Reconciliation of the incident population against the inventory, differences explained.
Day 8–12Map every statutory and contractual notification clock that could apply, and put the clock question ahead of the severity question in intake.Legal and privacy, with the incident process ownerThe notification matrix, with the awareness trigger stated for each obligation.A decision record for events assessed as not notifiable, which is the half most teams never keep.
Day 10–14Draft the incident communication plan against a real scenario from your own estate, then walk one past incident through it and see where it stalls.AI management system owner with communicationsThe communication plan: what constitutes an AI incident, who is told, on what timeline, in what form, who decides.A notification with its date mapped to the timeline the plan commits to — a plan no record demonstrates is a plan that gets tested in the audit.

The first row is the one to ship this week whatever else slips. A mandatory classification field starts building a population from the day it lands, and every week it is deferred is a week of data that cannot be recovered afterwards. The inventory row is the one most often underestimated: a record that cannot be joined to an assessed system by identifier cannot be trended and cannot be reported, so the inventory is the substrate for everything else here — building it is covered in the AI system inventory and registry.

Draft the communication plan against a real scenario from your own estate rather than a template, then walk one past incident through it end to end and see where it stalls. That walkthrough finds more design faults in an afternoon than a review cycle finds in a month. On fees, ISO 42001 pricing is all-inclusive and indicative: from $4,000 (₹3–3.5 Lakh) for small organisations, $5,000–6,000 (₹4.5–5 Lakh) for growing companies and $8,000 (₹7–10 Lakh) for large enterprises. It includes the accredited certification body’s audit fee. The certificate is issued by that certification body, not by Tranquility Cybersecurity, and the final figure depends on the certification body you choose.

Frequently Asked Questions

What is the difference between an AI incident and a normal IT incident?
An AI incident is one in which model behaviour, AI-generated content, autonomous decisioning or agent tool use materially contributed to the outcome. The practical test is counterfactual: if you removed the AI component, would the event still have happened in the same way, spread as far, and taken as long to detect? If the answer is yes, it is an ordinary incident that occurred near some AI. If any part of that answer is no, it is an AI incident too. Note the word too — most AI incidents are simultaneously security, privacy or availability incidents, and the right handling is to tag both rather than to pick one. The impact tags drive notification and severity, while the AI tags drive root cause and trending.
Do we need a separate AI incident register?
Usually not. The requirement is that AI incidents can be identified, investigated, trended and reported, not that they live in their own system. In practice that means a mandatory classification field at intake, the extra record fields captured from telemetry, the AI system owner on the escalation path, and a stored query that returns the population without anyone assembling it by hand. Three situations justify separation: a statutory reporting clock your general process cannot meet, a security incident procedure contractually scoped so narrowly that non-security AI events have no home in it, or a genuine product-quality tracker owned by an ML team — and in that last case the promotion criteria between the two must be written down.
Should every hallucination be logged as an incident?
No, and a register that contains every wrong sentence is not usable for the purpose anyone actually has for it. Use two tiers. Individual inaccuracies caught inside the review loop are quality signals: aggregate them, trend them, and act on volume. An inaccuracy becomes an incident when one of three things is true — (1) it escaped the loop and reached a customer, a regulator, a public channel or an automated downstream system, (2) it recurs as the same failure mode and is therefore systemic rather than an occurrence, or (3) it could plausibly have been high-impact even though it was caught. The third case is the near miss, and near misses are the most valuable entries a register holds because they carry the full causal chain without the harm.
What does ISO 42001 require about AI incidents?
ISO/IEC 42001:2023 does not prescribe an incident procedure in the way a security standard does, but several Annex A controls converge on one. A.8.4, communication of incidents, requires a documented plan for communicating incidents to users of the AI system, which the standard’s implementation guidance in Annex B.8.4 expects to cover what constitutes an AI incident, the notification timelines and the details to be reported — so the definition sits in guidance rather than in clause text, and the drafting is yours. A.8.3 covers external reporting of adverse effects, A.3.3 covers a mechanism for reporting concerns, and A.6.2.6 and A.6.2.8 cover operation and monitoring and the recording of event logs. Remember that Annex A controls are reference controls applied through the Statement of Applicability rather than blanket obligations. Above the Annex, Clause 9 requires monitoring, measurement, analysis and evaluation and management review, and Clause 10 requires nonconformity and corrective action. Certification is issued by an accredited certification body. An advisory firm can design and prepare, but cannot certify.
How does SOC 2 handle AI incidents?
Through the criteria it already has, which is why most organisations do not need a new control set. CC7.3 is the classification criterion: the entity evaluates security events to determine whether they could or have resulted in a failure to meet its objectives, and takes action if so. CC7.4 covers responding by executing a defined incident response programme to understand, contain, remediate and communicate. CC7.5 covers recovery. CC7.2 covers monitoring for anomalies, and CC4.1 supplies the evaluation layer above all of them. What changes for AI is not the criteria but the control descriptions and the evidence: your descriptions should make clear that AI-driven events are in scope, and your evidence has to include the run-level detail that makes an agent action investigable.
What fields does an AI incident record need that a normal one does not?
About twelve. (1) The AI system identifier from your inventory, (2) the model, version and deployment as configured at the time, (3) the provider, plan tier and processing region, (4) the trigger prompt, message or scheduled run, (5) the assembled context including system-prompt version, retrieved sources and connector scopes, (6) every tool call with parameters, results and denials, (7) the identity the agent acted under and on whose behalf, (8) the actions taken with the identifiers of what changed, (9) the human oversight status including whether a checkpoint fired and how long the approver spent, (10) the output disposition, (11) the guardrails and autonomy level in force, and (12) reversal, containment and correlation to related records. Most of these must come from telemetry rather than from a responder typing them, which makes the schema a platform requirement.
When does the EU AI Act require us to report an AI incident?
Article 73 obliges providers of high-risk AI systems placed on the Union market to report serious incidents to the market surveillance authorities of the Member State where the incident occurred. The report is due immediately after a causal link between the system and the incident, or its reasonable likelihood, is established, and in any event not later than fifteen days after becoming aware. Two shorter deadlines apply: not later than two days for a widespread infringement or a serious incident affecting critical infrastructure, and not later than ten days in the event of a death. Serious incident is defined at Article 3, point (49). The timing has moved, and this is the part most comparisons written before August 2026 get wrong: the AI Act, Regulation (EU) 2024/1689, was amended by the Digital Omnibus on AI, Regulation (EU) 2026/1744, in force 27 July 2026, which deferred stand-alone Annex III high-risk obligations to 2 December 2027 and Annex I embedded high-risk AI to 2 August 2028. For most organisations Article 73 is therefore a clock to design for rather than one already running — the exception being providers of general-purpose AI models with systemic risk, whose serious-incident duty under Article 55(1)(c) has applied since 2 August 2025. Settle the scoping question before your intake design, because these clocks run from awareness rather than from classification.
Is a prompt-injection attack an AI incident or a security incident?
Both, and treating it as only one of them produces the wrong remediation. It is a security incident because attacker-controlled content caused a system to take an action it should not have, and your security process owns containment, forensics and notification. It is an AI incident because the attack path runs through model instruction-following and tool selection, and the fix lives in capability scoping, confirmation design, provenance separation between trusted instructions and untrusted content, and output handling. Classified only as security, the remediation tends to become user awareness training, which does nothing about the mechanism. Classified only as AI, nobody runs the security response. Tag it as both and let each track do its own work.
How long should we retain AI incident and tool-call logs?
Longer than your reporting or observation period plus the lag before anyone asks for the evidence, which for most programmes means at least twelve to eighteen months for metadata. The trap is that distributed tracing and agent run logs are frequently retained for days or weeks by default while the assessment window is a year, so the gap is discovered when an auditor asks about a month that no longer exists. Prompt and output content is a different question because it may contain personal data: capture it narrowly, with a stated retention period, restricted access, a documented lawful basis and redaction on the ingest path. List every log store the record schema depends on, write its retention beside it, and export wherever retention falls short.
Our incident register only has a handful of AI entries. Is that a problem?
It is a problem only if there is nothing underneath it. A small register sitting on a written threshold, with several hundred aggregated signals below the line — evaluation failures, near misses, denied tool calls, user reports, override rates — is a credible picture and reads well. A small register with no aggregate data below it looks like an absence of detection rather than an absence of events, and that is how an assessor or a buyer will read it. The strongest position is to volunteer the threshold and the aggregate volumes before you are asked, because the question underneath the challenge is never why is this list short. It is whether you would have noticed.

Written By Expert Auditors

Surendra Pal SinghChief Information Security Officer & Data Protection OfficerCISODPOCISAMCSEITILISO 27001 Lead AuditorISO 27701 Lead AuditorISO 42001 Lead Auditor
Saundhi ChauhanLead AuditorISO 27001 Lead AuditorISO 27701 Lead AuditorISO 42001 Lead Auditor
Last reviewed: August 2026 • Content verified by certified lead auditors

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