Physical Validation for AI Vendors: What to Look For & How to Ask

The Conversational Approach

Effective physical validations are conversations, not interrogations. Rather than reading through questionnaire items sequentially, use the controls from your chosen AI risk framework: the NIST AI RMF, for example, as starting points for substantive discussion.

For each governance control, the goal is twofold: first, confirm that the vendor has the relevant policy or process documentation; second, have them demonstrate that the policy is actually being followed in production. The difference is significant. Many organizations have excellent documentation that has little relationship to actual practice.

For example, rather than asking "Do you have an AI inventory?" (a yes/no question that invites a "yes" response regardless of reality), ask: "Can you walk me through how you maintain your AI inventory? Who is responsible for keeping it current? When was it last reviewed? Can you show me a recent example?" This approach reveals both the existence of governance and the depth of its implementation.

What to Examine

Process walkthroughs for each NIST AI RMF Govern category give you visibility into legal and regulatory compliance, policy integration, risk management maturity, monitoring practices, inventory management, and decommissioning processes. For each area, ask to see the relevant documentation; then ask them to show you a recent instance of that documentation being used in practice.

Offshore Vendors

Offshore vendor validations follow the same fundamental approach but include additional physical security considerations. In many offshore environments, vendors handle sensitive client data in high-density work areas. Additional physical security checks, such as confirming policies on recording devices in production areas, verifying camera coverage and retention periods, and validating personnel background check processes, are appropriate and standard practice for offshore assessments.

Coming up next: Disengagement: the often-overlooked final chapter of the vendor relationship.