Risk · R-004 · Third-Party & Supply Chain

Third-party model and dataset provenance

A model, dataset or component is adopted from an external source with no verified account of where it came from, how it was made, what rights attach to it or how it has changed.

Severity
Medium
Audience
Heads-of · Practitioner
Frameworks
Principle 7 · Chapter V · Annex A.10 · AML.M0025
Reviewed
2026-11-11

What it is

Provenance is the history of an artefact: who produced it, from what, under what licence, and what has been done to it since. Models and datasets are easy to obtain from public repositories and resellers, and their descriptions are often thin or unverified. An organisation that builds on an artefact of unknown origin inherits whatever is in it: unlawful or biased training data, restrictive licence terms, poor quality, or deliberate tampering. This entry concerns not knowing. Deliberate compromise is covered in LLM supply chain vulnerabilities.

How it happens

  • A developer downloads a model from a public hub because it performs well.
  • A dataset is bought from a broker who cannot say how it was collected.
  • A supplier's product contains a third party's model that is not disclosed.
  • Versions are updated in place, so the artefact in use is not the one first assessed.

Why it matters

Questions about lawfulness of training data, intellectual property and fitness for purpose cannot be answered for an artefact with no history. A model is harder to inspect than code, so the record of its origin carries more weight.

Warning signs

  • Nobody can name the original producer of a model or dataset in use.
  • No licence terms are on file.
  • Artefacts are pulled from public sources at build time.
  • The model card or datasheet is missing or blank.

Mitigating controls

Primary controls

Third-party model and vendor due diligence Directive
Examines the origin, training and testing of an external model or dataset before use. Before an AI supplier, model or dataset is adopted, it is assessed against AI-specific criteria to a depth set by how material the use is, with evidence for the answers.

Supporting controls

AI bill of materials Detective
Records what was adopted and from where. The models, datasets, libraries, tools and hosted components that make up each AI system are recorded and checked against known vulnerabilities, licence terms and supplier changes.
AI incident response and rollback Corrective
Removes a component found to be compromised. When an AI system fails or produces harmful output, a defined procedure contains it, restores a known good state, preserves the evidence and manages the consequences.
Training data provenance checks Preventive
Verifies stated origins. The source, collection method, rights and integrity of every dataset are verified and recorded before it is used for training, fine-tuning or retrieval.

Framework and clause references

FrameworkClauseTitle
Code of Practice for the Cyber Security of AIPrinciple 7Secure your supply chain Supply chain.
EU AI ActChapter VGeneral-purpose AI model obligations GPAI training-data documentation obligations bear directly on provenance risk.
ISO/IEC 42001:2023Annex A.10Third-party and customer relationships Supplier relationships.
MITRE ATLASAML.M0025Maintain AI Dataset Provenance Dataset provenance.
NIST Generative AI Profile (NIST AI 600-1)Value Chain IntegrityValue Chain and Component Integration The value chain risk.

Sources

EU AI Act: Regulation (EU) 2024/1689 European Union (EUR-Lex) · official text
NIST Generative AI Profile NIST · framework
MITRE ATLAS MITRE · framework

Related terms

How to cite

Axiom Verity (2026). Third-party model and dataset provenance. Reference Library, R-004. https://axiom-verity.com/risks/third-party-model-provenance. Reviewed 2026-11-11.