What is the most common gap auditors find on MN-1.4?

Residual risk computed internally and never disclosed downstream

NIST AI RMF 1.0 · MANAGE - NIST AI RMF 1.0

`MN-1.4` Negative residual risks, defined as the sum of all unmitigated risks, to both downstream acquirers of AI…

Q: What evidence do auditors commonly ask for on MN-1.4 Negative residual risks, defined as the sum of all unmitigated risks, to both downstream acquirers of AI…?

The documented residual risk position after treatment; Identification of downstream acquirers and end users who bear residual risk; Evidence residual risk was communicated to those parties; The authority that accepted the residual position.

Negative residual risks (defined as the sum of all unmitigated risks) to both downstream acquirers of AI systems and end users are documented. What remains unmitigated is totalled and documented, and communicated to downstream acquirers and end users who inherit it.

Source: NIST AI RMF 1.0, MN-1.4. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST AI RMF 1.0 in the compliance library.

artefacts

held by a system

at each review

hard

to go live

Document repository

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Evidence residual risk was communicated to those parties · Document repository

governing documentDocuments that govern the control

The documented residual risk position after treatment · Document repository
Identification of downstream acquirers and end users who bear residual risk · Document repository
The authority that accepted the residual position · Document repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Residual risk computed internally and never disclosed downstream
Individual residual risks listed with no aggregate position
Residual position stale because treatments changed after it was recorded

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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MN-1.3 Responses to the AI risks deemed high priority as identified by the MAP function are developed, planned, and… · MN-2.1 Resources required to manage AI risks are taken into account, along with viable non-AI alternative systems…