Modulos vs Holistic AI: AI Governance Comparison (2026)

Modulos treats bias as a set of obligations with evidence behind them. The library holds IEEE 7003, the standard for algorithmic bias considerations, and NYC Local Law 144 for automated employment decision tools, next to the EU AI Act and its data governance duties in Article 10. A fairness audit is stored once as evidence and counts toward each framework that asks for it. Agent Tests then re-check the related controls on a schedule, for example whether a hiring model’s feature pipeline still excludes protected attributes.

Holistic AI grew out of algorithm auditing, and bias work is still where its depth shows. It has run independent NYC Local Law 144 bias audits for HR technology vendors such as Bryq. Its platform lists AI system audits that detect bias, hallucination and safety issues, plus red teaming to stress-test systems. For a buyer whose main exposure is unfair outcomes in hiring, lending or insurance, that audit practice is a real strength.

The Modulos edge: One piece of bias evidence can serve IEEE 7003, NYC Local Law 144, the AI Act and ISO/IEC 42001 at once, and scheduled checks keep the controls behind it under review.

For an AI provider or deployer in Europe, the AI Act rarely arrives alone. Modulos maps it with the Cyber Resilience Act, NIS2, DORA and GDPR at article level, in one library of 26 frameworks. EN 18286, the quality management system standard, became the first harmonised standard under the AI Act when its reference was published in the Official Journal on 14 October 2026. Applying it now gives a presumption of conformity with Article 17(1) and the first sentence of Article 11(1). The drafts next in line, prEN 18228 on risk management and prEN 18282 on cybersecurity, are already mapped. Of 929 controls, 453 serve two or more frameworks. Modulos experts serve on CEN-CENELEC JTC 21 and ISO/IEC JTC 1/SC 42, including JWG 6 on conformity assessment.

Holistic AI maps its controls to the EU AI Act, NIST AI RMF and ISO/IEC 42001, as its homepage states, and its built-in frameworks also include NYC Local Law 144. That set fits a programme centred on the AI Act and US bias law. However, we found no CEN-CENELEC harmonised standard in its catalogue, and no mapping for the Cyber Resilience Act, NIS2 or DORA.

The Modulos edge: One control set covers the AI Act, its first cited harmonised standard and the EU cyber and resilience rules around it, so a European audit draws on one body of evidence.

Scout, the Modulos AI agent, finds AI systems when a user asks it to. It lists Azure AI Foundry agents and Azure OpenAI deployments, inventories Microsoft Copilot Studio agents across a whole tenant, and reads usage from the customer’s OpenAI Platform organisation and Claude Console to show who uses AI through API keys. Access is read-only. Each find arrives as a Draft that a person confirms, and teams can import an existing inventory from CSV. Submitting a Draft starts registration: Modulos checks that the record is complete, runs an initial risk assessment and places the system in a review queue. A Registration Manager approves or rejects it with a recorded reason.

Holistic AI’s shadow AI discovery is described as continuously finding every ungoverned model, agent and application, scoring each by risk and reconciling it into a governed inventory. It connects through more than 20 read-only integrations, naming AWS, Azure, GitHub and Databricks, and Holistic AI says it built the module with GSK. For an organisation whose first problem is AI that nobody has declared, this is one of Holistic AI’s strongest features.

The Modulos edge: Every system Scout finds passes through a registration decision with a named approver and a first risk assessment, and the API-key view shows who calls OpenAI and Claude directly.

Agent Tests are how Modulos keeps conformity current after the audit. A person writes the check in plain English, and an agent with read-only tools runs it against connected systems daily, weekly, monthly or quarterly. Each run returns a pass, fail or error verdict with citations, and runs are stored immutably. A fail sets the mapped controls back to not executed and notifies their owners. An error leaves the controls as they are, and a pass does not restore a control by itself. Vijil is an integrated source, so its trust scores and probe results arrive as evidence on the same controls.

Holistic AI describes its Guardian Agents in two roles. Sentinel Agents watch and record AI activity and rate its risk, from anomalies to prompt injection and model drift. When a sentinel flags risk above a set threshold, Operative Agents act: they block unsafe requests, quarantine outputs for human review, revoke access and escalate to a person. Holistic AI publishes no fixed re-test cadence or scheduled audit interval, however. Its agents observe and intervene in real time, and Modulos runs scheduled checks whose verdicts change control state.

The Modulos edge: Each scheduled verdict is cited and kept, and a failure reopens its controls, which gives an auditor a dated conformity record for the months between audits.

The Fermi Risk Agent puts an annual loss figure in EUR, GBP or USD on each AI risk. It runs as a step in a scheduled job, so the number moves when controls or evidence change. The portfolio view drills from the organisation down to one threat vector, coloured by how much of each Risk Limit is used. Modulos completed ISO/IEC 42001 product conformity assessment with CertX (certificate 213-001/24) and holds a SOC 2 Type 2 report. Public references include Xayn, the first German company certified to ISO/IEC 42001, which was audit-ready in four weeks.

Holistic AI scores risk by category, weighing exposure, data sensitivity, organisational impact and artefact volume, but we found no published monetary method. Its trust centre lists ISO/IEC 27001:2022, achieved in February 2026 with no nonconformities raised, and a SOC 2 Type 2 report from April 2025. ISO/IEC 42001 is marked as in progress, and the trust centre states that Holistic AI is not certified today.

The Modulos edge: The board sees each AI risk in money, and Modulos already holds ISO/IEC 42001 product conformity while Holistic AI’s own ISO/IEC 42001 audit is still in progress.