Control · C-093 · Monitoring, Assurance & Incidents

Root-cause analysis and lessons learned

Significant AI incidents and near misses are analysed for their causes, including the control failures that let them happen, and the resulting actions are tracked to completion.

Control type
Corrective
Risks addressed
2
Audience
Heads-of · Practitioner
Frameworks
Article 17 · Clause 10 · MANAGE 4
Reviewed
2026-11-11

What it does

It stops the same failure recurring. After a significant incident or near miss, a structured review establishes what happened, why the system behaved as it did, why controls did not prevent or detect it sooner, and what should change. The review looks past the immediate technical cause to the decisions and gaps behind it. Actions are assigned, tracked and reported, and what was learned is shared with other system owners. The system owner is accountable for the review; governance tracks the actions. It operates after each qualifying event.

How to implement it

  • Define which incidents and near misses require a review.
  • Hold the review promptly, with people who were not responsible for the system as well as those who were.
  • Trace causes through data, model, prompt, integration, process and governance.
  • Record which controls failed, and whether each was missing, badly designed or not operated.
  • Turn findings into owned, dated actions, and add the failure to test suites and scenario libraries.
  • Share findings across teams, and report themes to the governance forum.

Evidence it operates

Design: a post-incident review procedure and template. Operation: review reports for qualifying incidents; an action log with completion evidence; test cases and scenarios added as a result; themes reported to governance.

Where it fits

After incident response has closed. It supports AI incident response gap and serious incident reporting failure, and it feeds AI failure scenario testing, the evaluation suite and AI risk reporting to the board.

Limits

For a complex model the technical cause may not be discoverable, and the review has to settle for the conditions that allowed harm. Reviews that look for someone to blame learn little. Actions tend to be closed on paper. Lessons recorded in one team's report rarely reach the others unless someone carries them.

Risks this mitigates

Supporting mappings

AI incident response gap High
Turns each incident into corrective action. AI-specific failures are not covered by the incident process: they have no classification, no playbook and no trained responders.
Serious incident reporting failure High
Root-cause findings complete the report to the authority. A reportable AI incident is not recognised, escalated or notified to the relevant authority within the time required.

Framework and clause references

FrameworkClauseTitle
Digital Operational Resilience Act (DORA)Article 17ICT-related incident management process Post-incident review.
ISO/IEC 42001:2023Clause 10Improvement Improvement and corrective action.
NIST AI Risk Management Framework (AI RMF 1.0)MANAGE 4Risk response, recovery and communication plans are documented and monitored Continual improvement.

Related terms

How to cite

Axiom Verity (2026). Root-cause analysis and lessons learned. Reference Library, C-093. https://axiom-verity.com/controls/root-cause-analysis-and-lessons-learned. Reviewed 2026-11-11.