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CSM6 AI Governance Implementation Guide

AI Governance Implementation Guide

A practical guide to applying the six CSM6 governance functions across the AI lifecycle.

For AI and system owners, product, engineering, security, data, risk, compliance, legal, architecture, program leadership and accountable executives.

6
Operating functions
6
Adaptable templates
48-hr
Governance baseline
Lifecycle
Risk-proportionate coverage

What the guide helps you implement

The framework page explains what CSM6 is. This guide explains how to operationalize it. For every function it provides objectives, questions to answer, minimum activities, example artifacts, responsible roles, evidence to retain, reassessment triggers, common failure modes, and optional HAIEC support.

Function 1

Purpose, Scope & Accountability

Intended use, accountable ownership, autonomy boundaries, and preliminary risk classification.

Example artifacts: AI use-case record · Ownership/RACI record · Intended-use statement · Preliminary risk classification
Function 2

System, Data & Dependency Mapping

Models, data sources, RAG, APIs, tools, agents, identities, permissions, vendors and dependencies.

Example artifacts: AI inventory record · System & data-flow diagram · Dependency register · Third-party inventory
Function 3

Risk, Evaluation & Monitoring

Risk assessment and evaluation before deployment; drift, anomalies and incidents during operation.

Example artifacts: Risk register · Evaluation plan & results · Acceptance thresholds · Monitoring plan
Function 4

Controlled Delivery & Change

Classify, approve and roll back meaningful changes; trigger reassessment for significant modifications.

Example artifacts: Deployment checklist · Approval & change record · Rollback plan · Exception record
Function 5

Human Oversight, Feedback & Learning

Human review, escalation, recourse, operator/user feedback, training and lessons learned.

Example artifacts: Oversight procedure · Escalation matrix · Feedback & training records · Lessons-learned register
Function 6

Compliance, Evidence & Assurance

Organize obligations, evidence and assurance across all functions. Compliance is cross-cutting.

Example artifacts: Applicability record · Control mapping · Evidence index · Assurance report
48-Hour CSM6 Quick Start

A 48-hour governance baseline

Within two focused working days you can establish an initial baseline — not complete governance implementation or compliance. This is a starting point, not a finish line.

Block 1

Purpose & Ownership

Inventory initial AI systems and identify accountable owners and intended use.

Block 2

System Mapping

Map models, data, integrations, agents and major dependencies.

Block 3

Risk & Evaluation

Identify material risks and missing evaluations; set initial priorities.

Block 4

Controls & Change

Identify approval and change-control requirements for meaningful changes.

Block 5

Oversight

Define escalation and human oversight requirements for high-impact decisions.

Block 6

Evidence & Roadmap

Capture existing evidence and build a prioritized remediation backlog.

This is a baseline, not complete governance implementation or compliance. The 48-hour quick start helps you identify priority systems, assign ownership, capture intended use, perform preliminary risk classification, map major dependencies, define initial evaluation/monitoring priorities, identify governance gaps, and create an implementation backlog. It does not guarantee every activity will be completed within 48 hours.

Adaptable templates

Templates included

Adaptable templates designed to accelerate implementation — not finished artifacts. Governance depends on organization, use case, sector, jurisdiction, risk, data, autonomy and operational context, so each template marks which fields require contextual adaptation.

AI System Inventory

Function 2

Record each AI system, model, provider, data sources and dependencies.

AI Risk & Evaluation Record

Function 3

Capture risk classification, evaluation plan, results and acceptance thresholds.

Change & Approval Record

Function 4

Classify changes, record approvals, rollbacks and exceptions.

Human Oversight & Escalation Plan

Function 5

Document oversight, escalation paths, recourse and operator guidance.

Incident Response Record

Functions 3 & 5

Record incidents, response, review and remediation to closure.

Compliance Evidence Index

Function 6

Index obligations, controls, evidence and assurance activities.

Industry starting points

Common use cases, risk categories and regulatory considerations — not universal requirements. Always qualify applicability and verify with qualified counsel.

Healthcare

Common use cases
Clinical documentation assistants · Triage and summarization · Patient-facing chat
Common risk categories
Patient safety · Privacy and PHI handling · Confidentiality
Regulatory considerations
May involve HIPAA or equivalent health-data rules for covered entities — applicability depends on role and jurisdiction. Verify with qualified counsel.

Financial Services

Common use cases
Underwriting assistance · Fraud detection · Customer support
Common risk categories
Fair treatment · Model risk · Regulatory reporting
Regulatory considerations
May involve sector rules, fair-lending obligations, or SOC 2 / ISO 27001 controls — none universally define governance for the sector. Verify with qualified counsel.

SaaS / Technology

Common use cases
In-product AI features · Code assistants · Support automation
Common risk categories
Customer data handling · Reliability · Vendor concentration
Regulatory considerations
Customer trust commitments, contractual obligations and privacy laws (e.g. GDPR/CCPA where applicable) often shape requirements. Verify with qualified counsel.

Startups

Common use cases
Internal productivity assistants · Prototype features
Common risk categories
Shadow AI · Unmanaged vendor use · IP and confidentiality
Regulatory considerations
A minimum viable governance baseline — ownership, inventory, material-risk review and evidence — is proportionate for early-stage use. It is not minimal compliance or a safe harbor.

Common pitfalls and how to avoid them

Four recurring governance failures, with better conceptual guidance for each.

"We'll add governance later"
Establish ownership, intended use and a preliminary risk classification from the start. Retrofitting governance onto live systems is harder and riskier.
"Just using an LLM API"
Third-party model providers still require vendor due diligence. You remain accountable for outputs, data handling, and subprocessors.
"Internal use only, so it's low risk"
Internal AI still requires proportionate risk assessment. Internal use can reduce some exposures but does not automatically eliminate privacy, security, IP, employment, confidentiality or operational risk.
"Use AI to govern AI"
Use deterministic or reproducible controls where consistency, traceability or enforcement is required. AI can assist governance activities, but probabilistic outputs should not silently become authoritative evidence or enforcement decisions without appropriate validation.

Reassessment triggers

These events re-open one or more functions. The guide walks through how to handle each.

New use case or expanded scope
New model, provider, or subprocessor
Significant prompt, config, dataset or knowledge-base change
New integration or expanded agent authority
Material incident or significant performance drift
New jurisdiction or regulatory change
Major vendor change or system retirement

How CSM6 relates to NIST AI RMF and ISO/IEC 42001

CSM6 is designed to support implementation activities that can be mapped to frameworks and requirements such as NIST AI RMF and ISO/IEC 42001. It complements them; it does not replace them.

NIST AI RMF is an iterative, risk-management framework organized around Govern, Map, Measure and Manage. ISO/IEC 42001 is an AI management-system standard focused on establishing, implementing, maintaining and continually improving an AIMS.

For laws (such as the EU AI Act or the Colorado AI Act), mapping claims are only made where relevant obligations, role/applicability, current citations and a mapping methodology exist. CSM6 does not claim universal regulatory coverage and does not determine applicability without context.

Proportionality is explicit

Governance depth depends on intended use, impact, autonomy, reversibility, data sensitivity, affected stakeholders, scale, regulatory exposure, and consequence of failure.

A low-impact internal assistant does not need the same depth as a system materially affecting employment, lending, healthcare or access to services. The guide keeps CSM6 practical rather than bureaucratic.

What this guide does not replace

Not legal advice.
Not certification.
Does not guarantee compliance.
Does not replace sector-specific requirements.
Does not determine regulatory applicability automatically without context.
Does not eliminate the need for qualified human judgment.
Does not require identical implementation for every AI system.
Does not replace NIST AI RMF, ISO/IEC 42001, or applicable laws.

Download the AI Governance Implementation Guide

A practitioner guide to the six CSM6 operating functions, with templates, a 48-hour baseline, industry starting points and reassessment triggers.

Six operating functions
Six adaptable templates
48-hour baseline
Industry starting points

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Next: assess your current AI governance

Understand the framework, download the guide, establish your baseline, then optionally use HAIEC tooling to operationalize it.