A plan, not a countdown
Nine moves that do not depend on the unpublished text.
The plan starts with the inventory and the description, because both are useful whatever the final wording says. It keeps the certifiable obligations in ISO/IEC 42001, where they belong, and treats the amendment as a vocabulary change. The planning date is an estimate and no transition period has been published.
| When | Move | What it involves | Units | Evidence to keep |
|---|---|---|---|---|
| Now | Name the owner and inventory the systems | List every ML-based system, mark the generative ones, and name one person who owns the description. Use the free check to record the starting position. | 1, 5 | A dated inventory and a named owner. |
| Within 30 days | Write the system description in the framework vocabulary | For each generative system record the task, the model family, the data and the tools. Separate the base model from the application and the fine-tune. | 6.2, 6.3, 6.4, 6.5 | A description a reader outside the team can follow. |
| Within 45 days | Record the architecture and the output handling | State whether the transformer is used encoder-only, decoder-only or encoder-decoder, and what the system does with generated output: labelling, review, retention. | 6.5.3.2.9, 6.5.3.2.10 | An architecture note and an output handling note. |
| Within 60 days | Write the synthetic data rule | Decide how much model-generated content can enter training or fine-tuning, record its provenance, and add a quality check across generations to catch model collapse. | 7.5 | A rule with a share limit and a generation check. |
| Within 75 days | Refresh the 42001 evidence | Update the AI system impact assessment, the statement of applicability and the risk register for the generative systems. These are the obligations that exist; the framework is the vocabulary. | ISO/IEC 42001 | Current impact assessment and statement of applicability. |
| Within 90 days | Take the board note and the management review | Write a one-page board note: what changes, what does not, what it costs. Put the amendment on the management review agenda with a date, and check whether any contract or scheme cites the base edition and needs a change note. | 6.5, 7.5 | A board note, a minute and a contract change note. |
| By 16 January 2027 | Ask the auditor in writing | Ask which description it will sample at the next audit, and whether it expects the published amendment or the current base edition. Record the reply and its date. | Audit basis | A written reply with the audit basis. |
| Planning date 16 February 2027 | Re-date the plan | If ISO publishes, read the text, replace every estimate with the published date and update the register. If it has not, keep the estimate and say so. | ISO stage 50.00 | A re-dated plan with the published or estimated status. |
| After publication | Map the final text and close the gaps | Compare the published additions with the draft summary, update the description, the synthetic data rule and the evidence list, and record the differences. | All units | A mapped register and a change note. |
What the kit adds
The free plan is the sequence. The USD 799 kit carries the same moves in a working register with an owner, a due date and an evidence pointer on every unit, plus the CSV and XLSX versions. See the kit.
Not legal advice; does not certify. The planning date 16 February 2027 is an estimate from ISO stage 50.00. The CEN date 4 April 2027 is the European adoption project's expectation.