Only buying AI and running several legal entities: how do you set the ISO 42001 scope?

Companies that do not train their own models can still implement ISO/IEC 42001: start by inventorying who uses which AI, which evidence you control and which you can only request from suppliers; with several entities and a shared platform, the certificate scope must match what you tell customers.

Updated 2026-10-29

Direct answer: ISO/IEC 42001 is for organisations that provide or use AI-based products and services; it is not limited to companies that train their own models. For a manufacturer that only uses purchased generative AI for summaries and coding help, the scope centres on use: which departments, which AI tools, which data, who approves and who is responsible when something goes wrong. With several legal entities and a shared AI platform, choose one business group or one entity as the first certification scope, write down the responsibilities for the shared platform, and expand later; do not let the certificate scope differ from what sales tells customers.

Five things to establish first

What to establishWhy it matters
Which AI systems exist, who uses them, what data they processWithout an inventory you cannot set the scope or answer customer due diligence
Whether you are a provider or a userUsers focus on rules of use, data input and output review; providers add life-cycle and documentation requirements
Which evidence you controlUsage records, approvals, training and output review are yours; model training data and tests usually have to be requested from the supplier
Boundaries between entities, sites and shared servicesWhen head office runs the platform and subsidiaries use it, the scope statement must say who is responsible for what
What you claim externallyA certificate covers only the organisation and activities in the scope statement; it cannot be stretched to "the whole group, all products"

What a consultant should deliver

How to accept the work

Every item in the scope statement maps to a system and an owner in the inventory; when a certification body samples any AI tool, it finds the approval, rules of use and training records; the scope sales describes externally matches the certificate.

What cannot be guaranteed

A narrow scope lets you certify sooner, but AI use outside the scope still carries risk; if customers require group-wide evidence, plan the expansion.

Winners Consulting's approach

The following describes Winners Consulting's own approach. Please test us with the same questions above, and test other consultants too.

Related questions

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Compliance needs all three; a consultant's value is integration

CRA, TISAX, ISO 27701 and the AI Act are not single technical problems. They are only complete when process, security technology and legal compliance all hold at the same time. Fix only one and the gaps in the other two surface during audits, incident reporting or customer due diligence, and the work has to be redone.

DimensionThe question it answersTypical gap when only this part is done
Process (management system)Who is responsible, what is done, when, where the evidence is, how it improvesTools are in place but nobody runs them on schedule, so there are no records at audit time
Security technologyHow controls are designed and how their effectiveness is verifiedDocuments are complete but the systems do not actually do what they describe
Legal complianceWhich regulation applies, which role you hold, the deadlines and penaltiesControls are built against the wrong regulation or role, so obligations are not covered

Winners' consulting team covers all three dimensions and plans regulatory scoping, process design and technical controls together, so a single body of evidence serves multiple regulations and customer requirements.

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