CF10-004: AI Incident Response Testing & Exercises

AI Control Library / CF-10: Recourse & Incident Response

Designation: Core | Control types represented: Operational and Technical

Control requirement

Exercise AI incident response against representative scenarios, testing human decisions, technical containment, evidence, communication and recovery. Verify corrective actions from the exercise.

Why this matters

A tabletop may reveal ownership gaps while a practical exercise reveals that the stop mechanism does not reach a child worker. Both forms can be useful, but neither should be claimed to prove untested capabilities.

How the control types work together

Operational controls define scope, authority and the actions required when conditions are not met. Technical controls produce evidence or enforce the relevant boundaries. Both must apply to the same deployment and operating conditions.

When it applies

AI response plans and cross-functional or supplier handoffs, proportionate to the deployment’s potential consequences.

Define the assessed boundary, dependencies and evidence limitations. Tailor depth and review frequency to potential impact, and document why a particular safeguard or exclusion is appropriate to the actual deployment.

Ownership

The exercise sponsor authorizes safe conditions; response and system owners evaluate outcomes and fund remediation.

Implementation guidance

  1. Set objectives, success criteria, participants, permissions and safeguards before selecting tabletop or technical exercises.
  2. Include uncertainty, absent contacts, supplier dependence and continuing actions where relevant to the scenario.
  3. Observe timing, authority, evidence preservation and actual containment without causing uncontrolled production effects.
  4. Record limitations and findings, assign owners and retest failed critical capabilities.

How to verify it

Use representative records and authorized controlled tests. Identify the relevant version, operating conditions and expected result before testing, and retain enough evidence to support the conclusion.

Test Expected result
Exercise a major response path Measured outcomes meet criteria or produce explicit gaps.
Inspect an untested dependency Reports do not imply it was verified.
Trace a critical finding Remediation and follow-up testing support closure.

Record a finding when required results cannot be demonstrated or practice differs materially from the approved conditions. Missing evidence limits the conclusion; it should not be treated as a successful test.

Evidence to retain

  • Exercise plan and safeguards
  • Observations and timings
  • Findings and ownership
  • Retest and readiness decisions

Protect evidence according to its sensitivity, access needs and retention rules. Avoid unnecessary copies of personal information, secrets or confidential material, while preserving the records needed for authorized review.

If the control fails

Escalate failed critical containment or recovery to incident and business owners. Apply interim restrictions while the response capability is corrected.

Example in practice

Hypothetical example: An exercise finds that the on-call responder cannot revoke a provider token. Access and alternative containment are corrected and tested before readiness is accepted.

Related controls

Framework mappings

  • CSA AICM (SEF-04)
  • NIST AI RMF (MANAGE 3.1)
  • EU AI Act (Art. 72)
  • ISO 42001 (Cl. 10.2)

Review and maintenance

Review at the interval approved by the control owner and after relevant changes, incidents or failed assessments. Update affected procedures and configuration, address evidence gaps and verify corrective action before closing findings.

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