For Critical Infrastructure Entities Using Hosted AI Reasoning Services
If your organisation is a Responsible Entity under Australia's Security of Critical Infrastructure Act 2018 (SOCI Act), and you use Azure OpenAI, AWS Bedrock, or any hosted AI reasoning service — you almost certainly have unaddressed gaps in your Critical Infrastructure Risk Management Program (CIRMP).
Most CIRMPs were written before AI APIs became embedded in operational workflows. They cover traditional IT vendors, OT/SCADA suppliers, and physical security — but not AI reasoning services that now influence scheduling, anomaly detection, customer communications, and operational control logic.
CIRMP Rules, Part 2
REs must identify all suppliers whose disruption could materially impact availability, integrity, or confidentiality of a critical infrastructure asset.
❌ AI API providers are rarely listed as material suppliers, despite being single points of failure.
SOCI Act Part 2B
REs must assess risks from foreign ownership, control, or influence over their supply chain.
❌ Most AI providers are US-headquartered with opaque ownership structures. Geopolitical risk is not theoretical.
Section 30AH
REs must maintain operational resilience, including the ability to continue essential services during supply chain disruptions.
❌ Most AI integrations have no failover path. When the API goes down, the dependent process stops.
Cross-border Data Flow
REs must understand where their data is stored, processed, and transmitted.
❌ AI API calls typically send operational data to US-based inference endpoints. Even "Australia East" deployments may route through global load balancers.
The "Personnel Filter"
REs must manage risks from personnel with access to critical systems.
❌ AI providers' SRE/ops teams have broad access to inference infrastructure. You have zero visibility into who has production access.
Incident Notification SLA
REs must report significant cyber security incidents within prescribed timeframes.
❌ If your AI provider experiences a breach, your reporting obligation is triggered — but you may not learn about it for days.
Single Point of Failure
REs must avoid undue concentration of risk in their supply chain.
❌ Many organisations use a single AI provider across multiple critical functions.
On February 28, 2026, a major cloud provider unilaterally suspended a customer's account with no prior warning, returning HTTP 403 for all API requests. AI-dependent workflows were immediately disrupted.
Key takeaway: Unilateral account suspension is a feature, not a bug, of cloud provider terms of service. Your CIRMP must account for it.