SC-AI-026 · Human oversight

Human oversight and override

Medium effortCovered by ISO 27001: New for AISatisfies 19 obligations in 13 policies

What it means

  • For each AI system, decide in writing what the AI may do on its own and where a person must check, approve or be able to step in.
  • Named, trained people can pause, override or switch off the system quickly, including a "kill switch" for serious harm.
  • Oversight is real: reviewers have time, information and authority to disagree with the AI.
  • ISO 27001 reuse: None. New for AI, not covered by ISO 27001. ISO 27001 documented operating procedures (A.5.37) can hold the SOPs, but the oversight design itself is new.

Why it matters

  • RBI FREE-AI asks for safeguards and SOPs before autonomous AI, human oversight for medium and high risk tasks, and the ability to shut an AI system down instantly.
  • The 2026 IT Rules require human oversight and periodic review of automated content detection tools at SSMIs.
  • MeitY advisories expect human oversight as part of safeguards against unlawful AI output.
  • Agentic AI that can send emails, move money or change records raises the stakes sharply.

Checklist

  1. For each inventory entry, record the oversight mode: human in the loop (approves each action), human on the loop (monitors and can intervene), or fully automated with sampling (SC-AI-004 AI risk classification and use-case tiering).
  2. Require human in the loop for high-risk decisions about people and for irreversible agent actions (payments, deletions, external communications).
  3. Write SOPs: what the reviewer checks, when to override, how to escalate, how to record the reason.
  4. Build and test a kill switch or feature flag that disables each AI system within minutes; name who may use it (SC-AI-033 Business continuity and fallback for AI).
  5. Set limits on agents: spend caps, rate limits, allowed tools, approval steps (SC-AI-030 Access control for AI systems and agents).
  6. Train reviewers on the model's known weaknesses and on automation bias (trusting the AI too much).
  7. Track override rates; very low rates may mean rubber-stamping, very high rates may mean the model is unfit.
  8. Review automated moderation or detection tools periodically for accuracy, fairness and bias.

Evidence examples

  • Oversight matrix listing each AI system, its risk tier and oversight mode.
  • Reviewer SOPs and training attendance records.
  • Kill switch test record (date, who triggered it, time to disable).
  • Override logs with reasons, and a monthly override rate report.
  • Agent configuration showing approval steps and spend or action limits.

Common pitfalls

  • "Human in the loop" that clicks approve on hundreds of cases an hour without reading.
  • Kill switch that exists only in a document and has never been tested.
  • Reviewers with no authority to overrule the model or no access to the inputs.
  • Agents given broad tool permissions "for convenience".

Satisfies

Also relevant to

Standards crosswalk

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

ISO/IEC 42001

  • A.6.2.6 operation and monitoring
  • A.9.2 processes for responsible use
  • A.9.4 intended use

ISO/IEC 27001

No direct equivalent

SOC 2

No direct equivalent

Key takeaways

  • Decide and record, per system, where a human must approve and where they only monitor.
  • A tested kill switch is part of oversight, not an optional extra.
  • Measure override rates to prove oversight is real.

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