Continuous systems need continuous assurance.
The review cycle should follow the rate at which material conditions can change.
A system can be compliant at approval and unreliable in production.
AI models drift. Vendors change. Data pipelines shift. Access patterns evolve. New integrations alter attack surfaces. A point-in-time review can establish a starting condition, but it cannot establish continuing reliability unless the system produces evidence between review dates.
Continuous assurance does not imply constant human inspection. It means instrumenting material conditions, identifying review triggers, preserving exceptions, and escalating when the institution's assumptions no longer hold.
NIST AI RMF Playbook: monitoring guidance emphasizes that deployed system performance and trustworthiness can evolve over time and requires regular monitoring and established response protocols.