What is the most common gap auditors find on MS-2.12?

Environmental impact declared immaterial with no measurement

NIST AI RMF 1.0 · MEASURE - NIST AI RMF 1.0

`MS-2.12` Environmental impact and sustainability of AI model training and management activities as identified in the…

Q: What evidence do auditors commonly ask for on MS-2.12 Environmental impact and sustainability of AI model training and management activities as identified in the…?

Assessment of energy consumption for training and inference; Water consumption and greenhouse gas emissions attributable to the system where applicable; The measurement basis and any published metrics adopted; Documentation of the assessment and its bearing on design decisions.

Environmental impact and sustainability of AI model training and management activities – as identified in the MAP function – are assessed and documented. The environmental cost of training and operating the system is assessed on stated measures, energy, water and greenhouse gas emissions, rather than treated as out of scope.

Source: NIST AI RMF 1.0, MS-2.12. 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

Assessment of energy consumption for training and inference · HR system / LMS

governing documentDocuments that govern the control

Water consumption and greenhouse gas emissions attributable to the system where applicable · Document repository
The measurement basis and any published metrics adopted · Policy repository / GRC workspace
Documentation of the assessment and its bearing on design decisions · 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

Environmental impact declared immaterial with no measurement
Training cost assessed while ongoing inference cost is ignored
Assessment held by the infrastructure team with no link to the AI system record

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.

Build my evidence sheet

MS-2.11 Fairness and bias as identified in the MAP function is evaluated and results are documented · MS-2.13 Effectiveness of the employed TEVV metrics and processes in the MEASURE function are evaluated and documented