Control · C-057 · Governance & Accountability

Shadow AI discovery

Network, procurement, expense and software records are reviewed on a set cycle to find AI tools and features in use that are absent from the inventory.

Control type
Detective
Risks addressed
3
Audience
Heads-of · Practitioner
Frameworks
Principle 5 · GOVERN 1
Lifecycle stage
Reviewed
2026-11-10

What it does

It finds the AI the organisation did not know it had. Independent data sources are searched for signs of AI use, the results are compared with the inventory, and each discovery is either brought into governance or stopped. Security owns the technical monitoring and the governance function owns the reconciliation. It runs continuously for network data and on a set cycle, at least quarterly, for the rest.

How to implement it

  • Monitor outbound traffic for known AI providers and for browser extensions.
  • Review expense claims and purchasing card data for AI subscriptions.
  • Scan software and cloud records for AI components and enabled features.
  • Review supplier release notes for new AI features in products already in use.
  • Ask staff, by survey, what they use and why.
  • For each finding, decide: approve and register, replace with an approved tool, or block.

Evidence it operates

Design: a discovery procedure listing sources, frequency and owners. Operation: discovery reports; inventory entries created as a result; records of tools blocked or replaced; a trend in the number of unregistered tools found.

Where it fits

Runs in operation as the check on intake. With the AI inventory it is a primary control for incomplete AI inventory, and with the AI policy for shadow AI use. What it finds is also evidence of unmet need, which should shape the approved toolset.

Limits

It cannot see use on personal devices and personal accounts outside the organisation's network. Providers and tools change faster than any list of them. Discovery used only to block and discipline teaches staff to hide; used to understand need, it reduces the problem at source. Monitoring of staff activity has its own legal limits.

Risks this mitigates

Primary mappings

Incomplete AI inventory High
Finds systems in use that the record lacks. 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.
Shadow AI use High
Finds unapproved tools from network, procurement and expense data. Staff use AI tools that have not been approved, placing organisational data and decisions outside any control.

Supporting mappings

Confidential information disclosed to AI tools High
Finds unapproved tools where the policy is bypassed. Trade secrets, legally privileged material or information held in confidence for others are entered into AI tools and leave the organisation's control.

Framework and clause references

FrameworkClauseTitle
Code of Practice for the Cyber Security of AIPrinciple 5Identify, track and protect your assets Identification of assets.
NIST AI Risk Management Framework (AI RMF 1.0)GOVERN 1Policies, processes and practices for AI risk are in place and effective Inventory completeness.

Related terms

How to cite

Axiom Verity (2026). Shadow AI discovery. Reference Library, C-057. https://axiom-verity.com/controls/shadow-ai-discovery. Reviewed 2026-11-10.