Third-Party Assurance for AI: Who Certifies?

The purchase committee asked which certificate made the agent 'government grade'. Four answers arrived in one afternoon: the vendor's ISO/IEC 42001, a SOC 2 Type II addressed to a US entity, a DPIIT recognition certificate, and a slide that said STQC-ready. None of the four reconstructed file 4418. None of the four was a lie, exactly. All four were the wrong object for the question.

India does not, today, offer a single statutory AI stamp that converts a chatbot into a lawful clerk. MeitY's 5 November 2025 guidelines prefer enabling practice and speak of voluntary codes. ISO/IEC 42001:2023 is a real international management-system standard. STQC exists as MeitY's Standardisation Testing and Quality Certification Directorate and can test products against named standards when you specify them. DPIIT recognition is about start-up status. Learn to keep these objects from collapsing into the word certified.

Explainer for DPOs and PAC committees. 16 August 2026. Not legal advice. Prcept will show tests you can fail. We will not sell you a halo.

A map of objects that are not synonyms

Ask for scope, date, who hired the auditor, and what was out of scope.

Object	What it is	What it is not
ISO/IEC 42001	AIMS certificate for an organisation	A case-level legal harbour
ISO/IEC 27001	Information-security management	Proof your prompt is versioned
SOC 2	An attestation to a service organisation's controls, often to a foreign entity	An Indian statutory filing
DPIIT recognition	Start-up eligibility	Sovereignty, residency, or safety
STQC test report	A lab result against a named standard you asked for	A general 'AI licence' unless that standard exists and was applied
Model card	Departmental documentation	A third-party certificate
Penetration test	A dated attack on a scope	A substitute for DFPR gates
MeitY guidelines alignment letter	A vendor essay	A Gazette

When a vendor says STQC-certified AI, ask which STQC scheme, which standard, which version of the product, which date, and whether the report is addressed to you. STQC is a real directorate. 'Ready' is a marketing tense.

Buy tests you can fail

Assurance that cannot fail is decoration. Write the tests into the bid: dark export of a case packet; isolation pcap if you claimed no outbound; DFPR tool-strip; refusal on child and payment; clock source; Indian-jurisdiction SIEM copy; training-ban technical proof. Hire a firm if you lack staff, but hire them against that list, not against a maturity poem.

If you want ISO 42001, read the scope. A certificate that covers the vendor's Delhi office and excludes the product you are buying is a poster. Ask whether your deployment is in scope. Ask for the nonconformities. A clean certificate with no findings is either a small scope or a shy auditor.

What still sits with you after the stamp

The public authority remains the authority. The Data Fiduciary remains the fiduciary. CAG still reconstructs cases. RTI still runs on 30 days. DFPR still names posts. A certificate is an input to the file. It is not the file.

DPDP operational duties from 13 May 2027 will not be discharged by an ISO number. They will be discharged by purposes, notices, processor contracts, security and rights. Keep the certificate in the annex. Keep the duties on the folio.

Two committees

Objections

Finance says a certificate reduces our risk. Answer: it reduces the risk of being asked whether you asked. It does not reduce the risk of a mute file.

A vendor says 42001 is the Indian AI Act. Answer: it is an ISO management standard. The Act has not arrived.

A consultant wants a new 'sovereign AI certificate' they will sell. Answer: treat it as marketing until a competent body publishes a scheme you can read.

Leadership wants only Indian certificates. Answer: prefer Indian labs for tests you specify. Do not reject a useful SOC report that happens to exist; read its scope. Do not accept an Indian logo that specifies nothing.

A four-week playbook

• Week 1: list the objects you have been shown. Re-label them with the table above.
• Week 2: write the fail-able tests into the bid or the CAB for the live system.
• Week 3: read one certificate's scope and nonconformities out loud in committee.
• Week 4: put 'certificates are annexes' into the Board folio. Put test results on the folio.

File note you can paste

Subject: Third-party assurance for agents — objects and residual duties.

This department does not treat ISO/IEC 42001, ISO/IEC 27001, SOC reports, DPIIT recognition, vendor 'guidelines alignment' letters, or model cards as a statutory harbour against DPDP, RTI, DFPR or CAG. Where a named STQC or sector test is required, the standard, date, product version and report addressee will be on the file.

Procurement will score fail-able tests (dark export, tool-strip, refusal, training ban, in-India logs) ahead of logos. This note is not legal advice.

How to read a scope page out loud in committee

Open the certificate. Read the organisation name. If it is a parent in another country, say so. Read the sites. If your SDC is not listed, say so. Read the statement of applicability or the equivalent exclusions. If 'customer deployments' or 'the product sold to government' is excluded, the logo on the cover is a neighbour's diploma. Minutes that record that reading will save you a year of implied reliance.

SOC 2 reports are often under NDA and addressed to a US entity. They can still be useful if you read the exceptions and the period. They are not a filing with MeitY. Do not let a committee treat a SOC bridge letter as a DPDP opinion.

If you commission STQC or another Indian lab, write the test method in the indent: isolation, logging, identity, whatever you actually need. A lab cannot invent your requirement. 'Please certify the AI' is how you get a polite report about something else.

Prcept will show DPIIT recognition when it is relevant to eligibility, and will still sit the dark-export and the DFPR strip. If a competitor has more logos and a mute tenant, the logos should lose. That sentence is how this cluster stays honest about our own paper.

• Ask for nonconformities. A certificate with none and a tiny scope is a poster.
• Ask who paid the auditor. Independence is a practice, not a watermark.
• Never write 'certified by CAG'. CAG audits. It does not logo your chatbot.

Informational explainer. Schemes change. Confirm live STQC offerings, sector circulars and ISO scopes before you describe any stamp as mandatory.

How this survives CAG, RTI or the Board

“Third-Party Assurance for AI: Who Certifies?” is not a workshop slide. A P6 Compliance/DPO will have to reconstruct a decision after the officer who clicked approve has been transferred. Write the artefact that lets a stranger replay the case: the log fields, the approval, the override, the register row.

There is no single Indian stamp that makes an agent lawful. ISO/IEC 42001 is a management-system certificate. DPIIT is eligibility. STQC is a lab you must name. Demand the test, the date, the scope, and what still fails. India AI Governance Guidelines (November 2025) are guidelines, not a statute. DPDP still allocates fiduciary duty. Delegation of Financial Powers still allocates who may spend. Do not hide those instruments behind the word governance.

If you cannot show who acted, on which purpose, with which data class, and who could have refused, you do not have accountability. You have a chatbot with a charter PDF.

• Name the owner of “AI certification India” inside the department, not the vendor.
• Keep CERT-In-relevant logs in India for the required period.
• Store overrides with a reason an auditor can read.
• Put the workflow on the AI register before it touches a citizen.

Close this loop before the next CAB

Put “Third-Party Assurance for AI: Who Certifies?” on the next change-advisory or bid-opening agenda as a single line item with an owner. If it cannot earn a line item, it will not earn a control. The owner should be a P6 Compliance/DPO, not “the vendor.”

Revisit the item when the model, the GeM term, the region, or the SI changes. “AI certification India” is not a one-time workshop. It is a watch item. Date the last check. Unsigned watch items are souvenirs.