Control · C-052 · Strategy & Risk Appetite
AI use-case intake and approval
Every proposed AI use is registered, screened, tiered and approved by a named authority before build or purchase begins, and again before it goes live.
- Control type
- Preventive
- Family
- Risks addressed
- 15
- Audience
- Heads-of · Practitioner
- Frameworks
- Article 9 · Annex A.5 · MAP 1
- Responsible AI domain
- Lifecycle stage
- Reviewed
- 2026-11-10
What it does
It gives every AI use a single way in. A proposal is recorded, screened against prohibited practices and the risk appetite, given a provisional tier, and routed to the assessments its tier requires. Nothing is built or bought until a named authority agrees, and nothing goes live until the conditions are met. A governance function operates the process; the business owner of the proposed use is accountable for submitting it.
How to implement it
- Provide one short intake form covering purpose, people affected, data, supplier and degree of autonomy.
- Screen at intake for prohibited uses and for personal data.
- Assign a provisional tier and the assessments that follow from it.
- Set approval authority by tier, with the highest tiers going to the governance forum.
- Connect intake to procurement, so a purchase cannot complete without it.
- Make approval of a new use of an existing system follow the same route.
Evidence it operates
Design: an intake procedure with approval authorities by tier. Operation: a register of proposals with decisions and dates; examples of proposals refused or changed; procurement records showing the check was applied; approval records for systems in production.
Where it fits
The first checkpoint in the lifecycle and the one that triggers the others. It feeds the AI inventory at source, starts AI risk tiering and prohibited-practice screening, and supports shadow AI use by making the approved route usable.
Limits
It only governs what is submitted. A slow or opaque process drives use underground, so speed for low-risk proposals matters as much as rigour for high-risk ones. AI features that suppliers switch on inside existing products never pass through intake unless something else finds them.
Risks this mitigates
Supporting mappings
- AI capacity and cost overrun Medium
- Tests the cost case before approval. Usage, latency or spend exceeds what was planned, degrading the service or the budget, without any attacker being involved.
- AI-driven social scoring Critical
- Ensures every proposed use reaches the screening. An AI system evaluates or classifies people over time on their social behaviour or personal characteristics, and the score leads to detrimental treatment that is out of context or disproportionate.
- Biometric categorisation of sensitive attributes Critical
- Ensures every proposed use reaches the screening. A biometric categorisation system categorises individuals from their biometric data to deduce or infer race, political opinions, trade union membership, religious or philosophical beliefs, sex life or sexual orientation.
- Exploitation of vulnerable groups by AI Critical
- Ensures every proposed use reaches the screening. An AI system exploits vulnerabilities arising from a person's age, disability or social or economic situation to distort their behaviour in a way that causes, or is likely to cause, significant harm.
- Incomplete AI inventory High
- Every approved use enters the record at source. The organisation cannot list the AI systems and models it builds, buys or uses, so risk assessment, oversight and regulatory duties are applied to only part of what it has.
- Individual criminal risk profiling Critical
- Ensures every proposed use reaches the screening. An AI system assesses or predicts the risk that an individual will commit a criminal offence, based solely on profiling them or on their personality traits and characteristics.
- Missing AI impact assessment process High
- Triggers the assessment when a use is proposed. AI systems are deployed without a structured assessment of who they affect, how, and what could go wrong for those people.
- Missing DPIA for high-risk AI processing High
- Screening at intake identifies processing that needs one. AI processing that is likely to result in a high risk to individuals goes ahead without a data protection impact assessment, or with one that was never updated.
- Purpose creep in AI data use Medium
- New uses of existing data pass through approval. Data collected for one purpose is used to train or run AI for another purpose that the people concerned would not expect.
- Real-time public biometric identification Critical
- Ensures every proposed use reaches the screening. Real-time remote biometric identification is used in publicly accessible spaces for law enforcement, outside the three narrow objectives and the authorisation the law requires.
- Shadow AI use High
- An accessible approval route reduces the incentive to go around it. Staff use AI tools that have not been approved, placing organisational data and decisions outside any control.
- Subliminal or manipulative AI techniques Critical
- Ensures every proposed use reaches the screening. An AI system uses subliminal, purposefully manipulative or deceptive techniques that materially distort a person's behaviour and cause, or are likely to cause, significant harm.
- Untargeted facial recognition scraping Critical
- Ensures every proposed use reaches the screening. An AI system creates or expands a facial recognition database through the untargeted scraping of facial images from the internet or from CCTV footage.
- Use beyond validated scope High
- A new use of an existing model goes through approval. A model approved for one purpose is reused for another, or for a new population, without reassessment.
- Workplace and education emotion recognition High
- Ensures every proposed use reaches the screening. An AI system infers the emotions of people at work or in education, for a purpose other than medical or safety reasons.
Framework and clause references
| Framework | Clause | Title |
|---|---|---|
| EU AI Act | Article 9 | Risk management system Risk management from the outset. |
| ISO/IEC 42001:2023 | Annex A.5 | Assessing impacts of AI systems Assessment before use. |
| NIST AI Risk Management Framework (AI RMF 1.0) | MAP 1 | Context is established and understood Context established before build. |
How to cite
Axiom Verity (2026). AI use-case intake and approval. Reference Library, C-052. https://axiom-verity.com/controls/ai-use-case-approval. Reviewed 2026-11-10.
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