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Building Your AI Controls Register: A Practical Guide for Australian Organisations
A controls register is the operational heart of your AI governance framework — it translates AI6 and Privacy Act obligations into specific, testable controls. This guide shows you how to build one that actually works.
Key Takeaways
An AI controls register documents the specific controls implemented to manage AI risk — mapped to AI6, the Privacy Act and sector-specific requirements. A policy says what should happen; a controls register documents what actually happens.
Controls fall into three categories: preventive (stopping harm before it occurs), detective (identifying when something has gone wrong), and corrective (restoring safe operation after a failure). A mature AI control environment needs all three.
For Australian organisations, AI6s six essential practices provide the most operationally relevant control structure, with Privacy Act obligations — including the December 2026 automated decision transparency requirement — as the mandatory legal floor.
Every AI system should have at minimum: a named accountability owner; a documented risk assessment; a Privacy Act compliance review; a human oversight mechanism; a monitoring schedule; and an incident response pathway.
Controls must be testable. We review AI outputs periodically is not a control — it is an aspiration. A testable control specifies who reviews, what they check, how often, what evidence is produced, and what happens when a problem is found.
The OAIC began its compliance sweep of privacy policies in January 2026 and moves to automated decision-making enforcement in December 2026. Organisations without documented controls will struggle to demonstrate compliance under scrutiny.
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Building an AI controls register for Australian organisations
An AI controls register documents the specific controls applied to each AI system — what they are, who owns them, how they're tested, and whether they're working. It sits alongside the AI risk register but focuses specifically on what the organisation is doing about the identified risks. For Australian organisations subject to APRA, ASIC, or Privacy Act obligations, the controls register provides the evidence that governance is operational, not just documented.
Controls framework
Structure controls around the regulatory expectations that apply: CPS 230 for operational risk; CPS 234 for information security; ASIC REP 798 findings for market conduct; Privacy Act for data protection; Anti-discrimination legislation for fairness; WHS obligations for worker-facing AI.
Preventive controls. AI policy and acceptable use standards; risk classification before deployment (tollgate/approval process); vendor due diligence before procurement; bias testing before deployment; DPIA before processing personal data; board approval for high-risk AI deployments.
Detective controls. Ongoing model performance monitoring; drift detection (PSI, KS tests); fairness monitoring across demographic groups; output sampling and human review; KRI monitoring with defined thresholds and escalation; incident detection and reporting; shadow AI detection (periodic discovery audits).
Corrective controls. Model rollback procedures; incident response and escalation; remediation tracking; regulatory notification procedures; customer remediation processes; vendor escalation and exit provisions.
Documentation per control
Each control should document: control name and description; which AI system(s) it applies to; which regulatory requirement it addresses; named owner (individual); testing methodology and frequency; last test date and result; evidence location (where test evidence is stored); status (effective / partially effective / ineffective / not tested).
Integration with APRA CPS 230
CPS 230 requires organisations to identify, assess, and manage operational risks. AI systems create operational risks that require controls. The controls register demonstrates to APRA that: material AI risks have been identified; controls are designed and implemented; controls are tested and effective; control failures are escalated and remediated. APRA's 30 April 2026 letter specifically expects continuous validation — meaning detective controls must operate on an ongoing basis, not annually.
Primary sources: APRA CPS 230 · ASIC