What is Special Controls?

In practice, special controls are the extra measures a company puts around a model or AI-enabled process when ordinary security, privacy, or operational controls are not enough. That can include stronger access restrictions, manual review thresholds, monitoring for misuse, content filtering, rate limits, or tighter approval workflows for high-impact outputs. The key compliance point is not just whether the controls exist, but whether they are selected based on a documented risk assessment and are effective for the specific use case.

These controls are especially relevant where AI can affect safety, rights, or regulated decisions. The EU AI Act requires risk management, human oversight, logging, and technical safeguards for higher-risk systems, while ISO/IEC 42001 and ISO 27001 both support control selection based on assessed risk. In practice, compliance teams use special controls to show that an organization has gone beyond generic security hygiene and implemented safeguards tailored to the AI system’s foreseeable harms, including misuse, model error, and unauthorized changes.