---
title: "Custom AI for the CRO"
description: "Model risk management is the discipline of identifying, measuring, monitoring, and controlling the risk of model failure across the lifecycle, from data ingestion through validation, deployment, chang"
url: https://impetora.com/for/cro
role: "Chief Risk Officer"
audience: "Chief Risk Officer"
trace_spine: "Readiness"
author: Impetora
---

# Custom AI for the CRO

> Audience: Chief Risk Officer. TRACE spine: Readiness.

Model risk management is the discipline of identifying, measuring, monitoring, and controlling the risk of model failure across the lifecycle, from data ingestion through validation, deployment, change-control, and retirement. AI does not replace this framework. AI sits inside it. Impetora designs every system to fit your existing three-lines-of-defence governance, with documentation that maps to SR 11-7 (5 lifecycle stages), the EU AI Act risk tiers (4 tiers, 8 Annex III categories), and DORA outsourcing obligations (5 ICT pillars).

## What CROs actually care about

### Model risk inventory

Every AI system in production in the inventory with owner, lifecycle stage, validation status, risk classification.

### EU AI Act risk classification

Each system classified against Annex III before shipping. High-risk triggers conformity assessment, data governance, transparency, human oversight obligations.

### DORA outsourcing

Article 28 sub-contracting and exit-strategy requirements where AI provider is third-party processor.

### Independent validation

First line builds, second line validates. Pack assembled by people independent of build team.

### Change control

A foundation-model upgrade is a model change. Change-control log captures trigger, impact assessment, validation, sign-off.

### Breach and incident reporting

Wrong, biased, or harmful outputs flow through breach-reporting workflow with evidence chain attached.

## TRACE pillar focus

For CROs, the spine is **Readiness**. See https://impetora.com/methodology for the full TRACE framework.

## Use cases

### Decision support

AI-augmented underwriting, claims, loan eligibility, fraud detection with full evidence chain. Validation pack and human-oversight design baked in.

### Document processing

Extraction with citation chain. Control sample reviewable, error rate monitored, change log auditable.

### Internal knowledge AI

Grounded answers across policies, regulator guidance, historical decisions.

### Process orchestration

Long-running workflows where AI is a participant and the deterministic spine carries risk-control checkpoints.

## What CROs need from a partner, and what we ship

### Risk classification memo

Each system classified against EU AI Act Annex III, GDPR Article 22, sectoral framework (SR 11-7, EBA, EIOPA, EMA, BCBS).

### Independent validation pack

Document set for second-line review: data lineage, evaluation set, performance metrics, refusal cases, edge cases, known limitations.

### Model inventory entry

Structured record: owner, version, lifecycle stage, validation status, residency, sub-processors, change history.

### Change-control workflow

Every model, prompt, retrieval-pipeline change goes through impact assessment and sign-off chain. Captured in audit log.

### Breach-reporting hooks

Misclassification, hallucination, policy violation routes through your breach-reporting workflow with evidence chain.

### DORA outsourcing pack

Sub-contracting register, exit strategy, incident-notification SLAs the regulation expects.

## CRO questions, answered

### Does TRACE map to SR 11-7?

Yes. Readiness covers development and implementation. Architecture covers use through versioned, observable, rollback-capable production. Citations covers validation through the evidence chain. Trust covers governance through residency, sub-processor, audit-log posture.

### How do you handle model change-control?

Every change is a controlled event. Foundation-model upgrades, prompt changes, retrieval-pipeline changes, tool-schema changes go through impact assessment, eval-suite rerun, three-lines sign-off chain. Logged with trigger, diff, test result, approver.

### What about DORA outsourcing requirements?

Contract includes Article 28 elements: written agreement, sub-contracting register, exit strategy, security and audit rights, incident-notification SLAs, regulator's right to access. Sub-processors disclosed and kept current.

### How is AI risk-classified under the EU AI Act?

Classified against the four-tier taxonomy in Discovery. Most enterprise systems land in limited-risk or high-risk under one of eight Annex III categories. High-risk gets the conformity-assessment scaffolding the regulation requires.

### Who does the independent validation?

Independent validation is performed by people independent of the build team. We deliver the validation pack as a structured artefact. Sign-off is your second line's. We can introduce a partner network of independent validators where needed.

## Contact

Email: info@ainora.lt
Discovery: https://impetora.com/for/cro#discovery-call