AI Risk Tracking: Tracking AI risks that resist measurement

Auditors ask about AI risk tracking early, because the answer tells them how the rest of the program is likely to look. The outcome is NIST AI RMF MEASURE 3.1.

What the framework says

Approaches, personnel, and documentation are in place to regularly identify and track existing, unanticipated, and emergent AI risks based on factors such as intended and actual performance in deployed contexts.

That is the text of NIST AI RMF MEASURE 3.1. Read it closely: it describes an outcome to achieve, not a product to buy, which is why two practices of the same size can satisfy it in different ways and both be right.

What this looks like in practice

In an assessment, NIST AI RMF MEASURE 3.1 is not one question. It resolves into several, and each one is really asking for different evidence. These are among the questions asked about it:

• Are approaches, personnel and documentation in place to regularly identify and track existing, unanticipated and emergent risks of this AI system in deployment?

Ownership usually sits with the model owner, though the evidence is often produced by someone else, which is where the trail breaks. A control that works but has no owner tends to stop working the month the person who quietly maintained it changes roles.

Who this applies to

NIST AI RMF is voluntary rather than binding, and that changes how it should be used. Adopting it does not create a legal obligation, and declining it is not a violation. It earns its place when a customer contract names it, when it gives structure to AI governance work you already owe under a law or a contract, or when a recognized practice is worth having on record. Treat it as a way of organizing that work, not as a second regime.

Building it, in order

The sequence below is the order that produces evidence as a by-product rather than as a separate documentation exercise:

1. Assign responsibility for tracking this system's risks in deployment.
2. Compare intended and actual performance on a set schedule.
3. Record new or emergent risks in the risk register.

Evidence an assessor asks for

For this outcome the evidence type that satisfies it is a procedure. The distinction matters more than it looks: a policy states what you intend to do, a procedure states how, and a record proves it happened on a date. Auditors ask for all three, and a practice that has written the first two often has nothing for the third.

Date every document and keep the superseded versions. The framework sets no retention period, so this is our recommendation rather than a requirement: keep each version for as long as the system it describes is in use and for a period after it is retired, because a question about a past decision is answered from the version that was in force when it was made.

Where this usually goes wrong

The usual gap is a control that exists in practice and nowhere in writing. Someone does the work, reliably, and it has never been written down, so the organization cannot demonstrate it and cannot notice when it stops. The fix is not more control, it is a dated record and a named owner.

What to do about it

• Produce the evidence, not the intention. For NIST AI RMF MEASURE 3.1 that means a step-by-step procedure someone unfamiliar with the task could follow. If the only evidence is that someone knows how this works, you have a practice and not a record.
• Put a name on it. The model owner should be recorded as the owner. A control with no owner stops working the month the person who quietly maintained it changes roles, and nobody notices.
• Set a review cadence and keep the evidence of each review. An annual date with a dated output is a common floor; what fails an assessment is a control implemented once and never re-checked against a changed environment.
• Do not treat this as a legal obligation. It is a voluntary framework. Adopt it where a customer contract or a regulator's guidance names it, or where it gives structure to AI governance work you owe for other reasons, and say in your own documentation which of those reasons applies.

The recurring lesson with AI risk tracking is that documentation is not the paperwork after the control. It is the part an assessor can read, and therefore the part that has to exist.

Related outcomes

• AI Fairness and Bias: Testing for bias in a clinical population
• AI Risk Treatment Decisions: Deciding to deploy, limit or decline
• AI Security and Resilience: Testing an AI system against adversarial input

References

• MEASURE 3.1, in NIST AI Risk Management Framework 1.0 (NIST AI 100-1). This is a voluntary framework, not a legal requirement. The quoted statement is NIST's own, from the Core tables of NIST AI 100-1.
• This post describes what a framework outcome asks for and what evidence documents it. It is not legal advice, and your counsel owns the conclusion. State law may impose additional obligations of its own.