October 20, 2026 by Ryan Bigelow
A few months ago, I was on a discovery call with an AI startup exploring multiple compliance frameworks.
That in itself was not unusual. Over the past year, I have participated in more than a dozen similar conversations with emerging AI companies. What caught my attention was the timeline.
“We need to be certified in under four weeks because that’s when the NVIDIA conference is.”
The company had a promising product and ambitious growth plans. Customers and prospective partners were asking questions about security and compliance. What the company did not yet have was a mature security program capable of supporting the certifications it hoped to obtain.
The conversation reflected a broader trend across the AI marketplace. Startups are racing to bring products to market, while customers and investors are demanding proof that those products are secure. This creates pressure to obtain certifications, attestations, and audit reports as quickly as possible.
The problem is that security maturity does not operate on the same timeline as product launches, funding rounds, or industry conferences.
The rapid growth of artificial intelligence has created a surge of new vendors, platforms, and products. Many of these companies did not exist two years ago, yet they may now be trusted with customer data, intellectual property, source code, or other sensitive information.
These organizations are often led by highly capable engineers, researchers, and data scientists focused on product development, customer acquisition, funding, and growth. Information security, risk management, and compliance may receive sustained attention only after customers begin requesting evidence.
That does not mean AI startups are intentionally disregarding security. Many simply have not had the time, resources, or experience needed to build a mature program.
A product can be innovative and technically impressive while still being supported by an immature security environment. This is precisely why Third-Party Risk Management, or TPRM, matters.
One of the most noticeable changes in recent assessments is the increased use of AI-assisted policies and procedures.
This is not inherently a problem. AI-generated documentation is often more polished, comprehensive, and readable than the generic templates organizations previously relied upon. It can provide a useful starting point and help organizations address security topics they may otherwise have overlooked.
The concern arises when the documentation does not reflect what the organization is actually doing.
A policy might state that access reviews are formally documented and completed every quarter. When the evidence is requested, the organization may discover that reviews are performed inconsistently, documented informally, or have not yet been implemented.
AI can produce hundreds of pages of governance documentation in minutes. Implementing the processes, configurations, training, and oversight described in those documents still takes time.
The issue is not whether AI helped write the policy. The issue is whether the policy describes reality.
Vendors may have formal policies, completed questionnaires, trust centers, compliance badges, and independent assessment reports. Those materials are generally positive, but their presence should represent the beginning of a review rather than the end.
The relevant question is no longer simply, “Does the vendor have security documentation?”
The better question is, “How much confidence do we have that the vendor operates as described?”
Answering that question requires understanding what was assessed, whether the scope applies to the services being purchased, what evidence was tested, and who performed the assessment.
A SOC 2 report, PCI DSS Attestation of Compliance, or ISO certification can provide valuable assurance. However, not every assessment is performed with the same level of quality, independence, or professional judgment.
The market includes firms offering extremely inexpensive assessments, compressed timelines, and guaranteed outcomes. This creates a risk that testing will be rushed, heavily templated, or performed without enough evidence to support the conclusions.
When reviewing third-party assurance, organizations should consider:
Audit and certification firms become part of the trust chain. Their credibility matters.
Even a high-quality report provides limited value if no one reads it. Collecting a SOC 2 report, PCI DSS AOC, or ISO certificate and saving it to a vendor file is not the same as reviewing it. Organizations must evaluate its scope, findings, subservice providers, customer responsibilities, and relevance to the services being used.
Vendor questionnaires and trust centers can support an effective TPRM process, but neither should be treated as conclusive evidence.
Questionnaire responses may be vague, overly optimistic, or based on what a vendor intends to do rather than what it currently does. AI also makes it easier to produce polished and convincing responses without demonstrating that the stated controls are operating.
Trust centers make assurance documentation easier to distribute, but their content may be carefully curated. Reports may be outdated or apply to only part of the vendor’s services. Policies may be templated, and important limitations may not be obvious.
Transparency matters. If a vendor refuses to provide relevant assurance documentation or makes critical reports available only through higher-priced service tiers, that should be considered during the risk evaluation.
Traditional vendor reviews remain important, but AI products introduce additional considerations. Organizations should understand:
Without clear answers, an organization may unintentionally expose client information, pricing, intellectual property, source code, or internal communications.
The risk is not limited to approved vendors. Employees may independently use AI tools and upload sensitive information to platforms that have not undergone security, privacy, legal, or procurement review. TPRM must therefore be supported by clear internal guidance on approved AI technologies and acceptable data use.
The purpose of TPRM is not to eliminate risk or prevent the business from adopting new technology. Its purpose is to support informed decision-making.
Not every startup should be rejected because it lacks a lengthy compliance history. An organization may reasonably choose to proceed based on the value of the product and the risk involved. That decision should consider the sensitivity of the data, the importance of the service, the maturity of the vendor, and the quality of the available assurance.
The objective is not to demand perfection. It is to understand the risk being accepted and determine whether the vendor’s security claims are supported by credible evidence.
At FoxPointe Solutions, we help organizations build strong, sustainable security and compliance programs and demonstrate their effectiveness to customers, business partners, and other stakeholders through high-quality independent assessments.
Our focus is not on shortcuts, guaranteed outcomes, or producing a certificate as quickly as possible. We work with clients to understand the requirements that apply to their environment, identify gaps, implement meaningful controls, and prepare for assessments that can withstand scrutiny.
AI can help organizations create better documentation, organize evidence, and streamline routine compliance activities. However, it cannot replace effective controls, organizational accountability, experienced assessors, and credible assessment work.
