SC-AI-014 · Model lifecycle

Model documentation (model cards, system cards)

Medium effortCovered by ISO 27001: New for AISatisfies 19 obligations in 10 policies

What it means

  • Each AI system has a short, standard document explaining what it is for, how it works, what data it used, how well it performs, and where it should not be used.
  • A model card covers a single model; a system card covers the whole application (model plus prompts, retrieval, guardrails, human steps).
  • For bought models, include what the vendor tells you plus how you configured and tested it.
  • Kept current: updated on each significant change, versioned alongside the model.

Why it matters

  • RBI FREE-AI expects documentation of objectives, design, context and benchmarks from design to decommissioning.
  • Validators, auditors and incident responders all need it; without it every review starts from scratch.
  • Enterprise customers and government buyers increasingly ask for model or system cards.

Checklist

  1. Adopt a model card template: purpose, intended users, out-of-scope uses, model type and version, training data summary, performance metrics, fairness results, known limitations, owner, approval date.
  2. Add a system card template for applications combining models, prompts and tools.
  3. Complete cards for all medium and high risk systems before go-live.
  4. Store cards with the model in the registry or repository, versioned.
  5. Update the card on every material change (SC-AI-019 Change management and approval gates).
  6. Prepare a customer-facing version where customers or buyers need it.

Evidence examples

  • Model card v2.3 for the fraud detection model with approval sign-off.
  • System card for the customer service GenAI assistant describing prompts, retrieval sources and guardrails.
  • Model registry screenshot showing card linked to the deployed version.
  • Change log showing card updated after retraining.

Common pitfalls

  • Cards written once for launch and never updated.
  • Too technical for business owners, or too vague for validators.
  • No "do not use for" section, so the model gets reused for a purpose it was never tested for.

Satisfies

Also relevant to

Standards crosswalk

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

ISO/IEC 42001

  • 7.5 Documented information
  • A.4.2 Resource documentation
  • A.6.2.3 Documentation of AI system design and development
  • A.6.2.7 AI system technical documentation
  • A.8.2 System documentation and information for users

ISO/IEC 27001

No direct equivalent

SOC 2

No direct equivalent

Key takeaways

  • One standard card per model or system, versioned with the model.
  • New for AI, not covered by ISO 27001. Your document control habits carry over, but no Annex A control asks for model documentation.
  • Include limitations and out-of-scope uses, not just performance.

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