The Gaps Between the Frameworks

NIST AI RMF, ISO/IEC 42001, and the EU AI Act each serve a distinct purpose, but none gives an organization a complete operating model. This companion document identifies four practical gaps: fragmentation across frameworks, ownership that is named but not operationalized, limited treatment of agentic AI, and retirement treated as an afterthought. It shows how the Digital Trust and Accountability program addresses each gap without claiming to replace the underlying frameworks.