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AIG-009 AI System Deployment and Change Management

Tier 2+AIProviderDeployerGPAI Model ProviderManaged Service Provider

Description

A documented deployment plan exists for each production AI system and pre-dates its deployment record. The plan records the pre-deployment checks completed, the verification and validation sign-off, the impact assessment it relies on, the rollback procedure and the communication to affected users. The deployment policy defines what counts as a substantial modification and gives worked examples. The record for each substantial modification shows the same pre-deployment checks completed as for a first deployment.

Rationale

Ungated model changes are a leading cause of AI production incidents, because a retrained model can pass every infrastructure test and still behave differently on the traffic that matters. Teams most often disagree over what counts as a substantial modification. Without worked examples covering a training data source change, an architecture change and an inference threshold change, the same change is gated by one team and waved through by another. AIG-008 holds the verification and validation gate this plan cites. The conformity assessment that a regulated system repeats after a substantial modification is a separate obligation the library does not yet carry.

Applicability (9 profiles)

SaaS AI Providerstablerequiredcore
Enterprise AI Deployerstablerequiredcore

The deployment plan and the substantial-modification definition are the deployer's. The same definition is the Art.25 test: a substantial modification makes the deployer the provider.

GPAI Model Providerstablerequiredcore
High-Risk Provider (EU)stablerequiredrisk class duty

Art.43(4) attaches an external consequence to the substantial-modification definition this control already carries: the conformity assessment is repeated whether or not the system is distributed further or continues in service. The definition and its worked examples are therefore the trigger for a procedure outside the organisation and not only for the internal pre-deployment checks. Changes predetermined and documented in the initial assessment for a continuously learning system are outside it, which is what makes writing them down at first assessment pay. AIG-037 holds the repeated assessment and the reissued declaration.

Public Body Deployer (EU)stablerequiredcore

The deployment plan and the substantial-modification definition are the deployer's. The same definition is the Art.25 test: a substantial modification makes the deployer the provider.

DORA ICT Provider (EU)stablerequiredcore
NIS2 Cloud Provider (EU)stablerequiredcore

Framework Mappings (15)

MDS-05Model Documentation Validationinformative
EU-AI-Art.43.3Conformity Assessment — Reassessment After Substantial Modificationinformative
A.6.2.5AI system deploymentfull
GV-1.3-002Risk Management Activity Level Determination | GV-1.3-002informative
GV-1.3-007Risk Management Activity Level Determination | GV-1.3-007informative
MG-1.3-001High-Priority Risk Response Planning | MG-1.3-001informative
MG-3.1-001Third-Party AI Risk Monitoring and Controls | MG-3.1-001informative
MG-3.1-003Third-Party AI Risk Monitoring and Controls | MG-3.1-003full
MP-4.1-007AI Technology and Legal Risk Mapping | MP-4.1-007full
MS-2.3-003AI System Performance Measurement | MS-2.3-003full
MS-2.7-008AI System Security and Resilience Evaluation | MS-2.7-008full
MS-4.2-005Trustworthiness Measurement with Expert Input | MS-4.2-005informative
MANAGE 1.1AI System Purpose and Deployment Determinationinformative
MANAGE 4.1Post-Deployment AI System Monitoringpartial
MANAGE 4.2Continual Improvement Integrationpartial

Evidence (2)

recorddocumentmanual

Completed pre-deployment checklist for each AI system deployment or substantial modification, documenting V&V sign-off, impact assessment completion, rollback procedure availability, and deployment approval.

Example: AI Deployment Checklist · Recommendation Engine v2.1 (Jira ticket AI-1203), showing all gates passed, rollback procedure linked, and sign-off by AI system owner on 2026-01-08

Test: Request pre-deployment checklists for a sample of recent AI system releases. Verify: (1) V&V sign-off is recorded, (2) impact assessment is referenced and completed, (3) rollback procedure is documented and linked, (4) operator runbook is available, (5) an authorised owner has approved the deployment, (6) the definition of 'substantial modification' is applied consistently.

policydocumentmanual

AI deployment and change management policy defining the required gates, rollback requirements, and the definition of 'substantial modification' that triggers full pre-deployment controls.

Example: AI Change Management Policy v1.1 (Confluence), defining substantial modification examples (training data source change, model architecture change, inference threshold change), required checklist items, and approval authority per tier

Test: Request the AI deployment/change management policy. Verify: (1) 'substantial modification' is defined with concrete examples, (2) required pre-deployment artefacts are enumerated, (3) rollback procedure requirement is stated, (4) approval authority is defined per AI risk tier, (5) policy applies to third-party model updates where the organisation is deployer.

Questions (2)

boolean

Does a documented deployment plan exist for each production AI system, dated before its deployment?

The plan is the artefact, not the intention. An assessor compares the plan date against the deployment record date for a sample of releases; a plan written after go-live does not meet the control.

multi

Which of the following does the deployment plan record for each production AI system?

The pre-deployment checks completedThe verification and validation sign-offThe impact assessment it relies onThe rollback procedureThe communication to affected usersThe definition of a substantial modification, with worked examplesThe same pre-deployment checks completed for each substantial modificationNone of the above

Options run from the most commonly recorded to the least. Without a worked definition of a substantial modification, teams reach inconsistent judgements about when a change needs the full gate. Retraining on a new data source and a change to an inference threshold are the two cases worth naming.