AI/LLM Workflow Inventory and Ownership for SOC 2

What this control should accomplish

Every production AI or LLM workflow has a known purpose, owner, risk classification, data boundary, model dependency, and approval status.

How to implement AI/LLM Workflow Inventory and Ownership

1. 1

   Define inventory scope

   Specify which applications, agents, retrieval services, automations, and embedded model features count as production AI workflows.

   You should end up with: Documented AI inventory boundary

2. 2

   Record each workflow

   Capture purpose, users, owner, model and provider, tools, data types, customer impact, environment, and current status.

   You should end up with: Complete workflow register entries

3. 3

   Classify practical risk

   Apply defined tiers based on data sensitivity, autonomy, external impact, privileged actions, and dependence on generated output.

   You should end up with: Risk tier with recorded rationale

4. 4

   Review inventory changes

   Reconcile the register with deployed services and approve new, materially changed, dormant, or retired workflows.

   You should end up with: Dated inventory review and decisions

Evidence to keep, and what it should prove

Build the evidence set in three layers: what defines the control, who approved or reviewed it, and what proves it operated. Collect operating records when the work happens so they remain dated, attributable, correctly scoped, and traceable to the underlying activity.

Before sharing, remove unrelated personal or customer data, never expose passwords, tokens, or secret values, preserve enough source context to authenticate the record, and use the secure exchange approved for the engagement.

Which records should you prepare for the audit?

How an auditor may test this control

Use this checklist to prepare for procedures an auditor may perform. The exact steps and sample selection depend on your engagement scope and the service auditor's professional judgment.

• Confirm the intended control outcome

  Determine whether the control is designed to achieve this result: Every production AI or LLM workflow has a known purpose, owner, risk classification, data boundary, model dependency, and approval status.

• Confirm ownership and operating cadence

  Compare the documented owner with the intended role (AI Workflow Owner / CISO / Engineering), then compare dated records with the stated cadence: Per workflow/change; review at least annually.

• Establish the complete audit record set

  Reconcile the register to production model-gateway clients, cloud AI resources, deployed services, and repositories; explain unregistered runtime callers and verify retired workflows no longer execute.

• Prepare the as-of-date evidence for a Type 1 engagement

  Retain the current workflow register with approved owners and risk decisions plus the latest completed inventory review as of the selected date.

• Prepare period evidence for a Type 2 engagement

  Account for every AI workflow active at any time during the period and every new, materially changed, suspended, or retired workflow, together with each scheduled inventory review and resulting ownership or risk decision.

• Inspect the policy / design artifacts

  Documents that define the control, its scope, ownership, and expected way of working.

  • Inspect AI workflow inventory

    For each selected record, confirm it demonstrates All active, planned, dormant, and retired production AI workflows are identifiable with their purpose, components, data use, risk, and status.

    • Workflow ID
    • Purpose
    • Environment
    • Model and provider
    • Data categories
    • Risk tier

  • Inspect owner assignments

    For each selected record, confirm it demonstrates Business and technical accountability is explicitly assigned for each workflow and remains current.

    • Workflow ID
    • Business owner
    • Technical owner
    • Assignment date
    • Responsibilities
    • Approval

• Inspect the approval / review evidence

  Records showing that an accountable person reviewed, approved, challenged, or accepted the work.

  • Inspect risk classifications

    For each selected record, confirm it demonstrates Each workflow received a repeatable risk decision based on its data, autonomy, impact, tools, and output reliance.

    • Workflow ID
    • Risk tier
    • Decision factors
    • Assessor
    • Assessment date
    • Required safeguards

  • Inspect review records

    For each selected record, confirm it demonstrates An authorized reviewer periodically confirmed workflow scope, owner, risk, approval status, and required follow-up.

    • Review date
    • Inventory scope
    • Reviewer
    • Decisions
    • Exceptions
    • Action owners and due dates

• Trace the control from design to operation

  Use the categories that apply to this control: connect any policy or design artifact to its approval or review record, then trace a selected operating record through execution, result, and any exception or remediation.

Common implementation and evidence gaps

• The register covers sanctioned products but misses experiments that reached production.
• A team name is listed instead of an accountable individual role.
• Risk tiers have labels but no repeatable decision factors.
• Retired workflows remain connected to providers, tools, or data.

Before you call this control ready

• Can deployment and gateway records be reconciled to the workflow register?
• Does every active workflow have business and technical accountability?
• Would a model, tool, or customer-data change trigger reassessment?
• Are disabled workflows removed from credentials, integrations, and monitoring?

Trust Services Criteria references

These identifiers help you navigate related Trust Services Criteria. They do not reproduce the criteria or prove that this control fully addresses them in your environment.

• CC2.1
• CC3.2
• CC5.2
• C1.1
• P4.1

Confirm final scope, mappings, and testing expectations with your service auditor. SOC 2® is an AICPA trademark; GreenHat Security is not affiliated with or endorsed by AICPA.

Related controls to review next