What the September 2026 ISM requires for AI agents

Eight controls now govern AI agents. None maps to the Essential Eight, so nothing you already report covers them.

Last reviewed: · 4 min read

The short answer

The September 2026 Information security manual requires that every AI agent has its own identity, that you keep a register of those agents, and that an agent can only reach the minimum set of tools it needs. Seven controls are new. One that already existed was made stricter.

The requirement most organisations fail immediately is the register. ISM-2135 asks which tools and data each agent can reach, and that answer lives in configuration rather than in a document someone can write.

Identify the agent and write it down

These three sit in the ISM chapter on system access. That placement is the clue: an agent is treated as something holding access, not as a feature of an application.

AI agent identity and register controls, September 2026 ISM.
ControlWhat the ISM saysWhat it means in practice
ISM-2133Each AI agent is assigned a unique identity that is distinct from the user accounts of personnel and the identities of other AI agents.An agent cannot run as a person, and two agents cannot share one identity.
ISM-2134An AI agent register is developed, implemented, maintained and regularly verified.The register has to exist, stay current, and be checked against reality.
ISM-2135An AI agent register contains the following for each AI agent: its unique identifier; its owner and business purpose; the identities assigned to it; any user accounts and credentials it uses; and the tools, permissions and data repositories it can access.Five fields per agent. The last one is the one nobody has.

Giving each agent its own identity sounds administrative until you try it. Most deployments authenticate as the person who triggered them, or as one shared service account. Both are now the wrong answer.

Constrain what the agent can do

These four sit under excessive agency in the software development chapter, describing the failure mode where an agent can do far more than its purpose requires.

Excessive agency controls, September 2026 ISM.
ControlWhat the ISM saysWhat it means in practice
ISM-2156Agentic AI applications are restricted to the minimum set of tools, functions and permissions required for their intended purpose.Least privilege, applied to the tool list rather than to a role.
ISM-2157Tools invoked by agentic AI applications are subject to both the access controls of the invoking user and agent-specific, task-scoped authorisation, with effective permissions limited to the minimum permitted by both.The agent gets the intersection of its own scope and the user it acts for.
ISM-2158External content retrieved by agentic AI applications is treated as untrusted data throughout processing, is clearly delimited from system instructions, is subject to validation and sanitisation measures applied to other untrusted input, remains untrusted following such processing, and is prevented from modifying or overriding system instructions, security policies, access controls, tool permissions or human approval requirements.Retrieved content stays untrusted even after sanitisation, and can never change the rules.
ISM-2159All tool invocations, external requests and outputs generated by agentic AI applications are centrally logged with sufficient detail to support cyber security incident investigations.Tool calls and outputs, centrally, at a detail level an investigation can use.

ISM-2157 is the demanding one. The agent gets the intersection of its own task-scoped authorisation and the permissions of the user it acts for. An agent inheriting an administrator's rights because an administrator asked it a question does not satisfy this.

ISM-2158 catches retrieval systems. External content stays untrusted even after sanitisation, and can never override system instructions or approval requirements.

The control that got stricter

Amended control, September 2026 ISM.
ControlWhat the ISM saysWhat it means in practice
ISM-2113AI applications are configured to require human approval before executing sensitive or high-impact actions.Approval is now required for sensitive actions, not just flagged for a human to notice.

The earlier wording asked that risky actions be flagged for approval. It now requires approval before a sensitive action executes. Flagging is something you add to a log. Requiring approval is something you have to build.

Why the Essential Eight does not help here

All eight are published with no Essential Eight mapping, and so are the other 36 controls added in this release.

  • Essential Eight Maturity Level Three does not address any of the eight.
  • Posture tools reporting against the Essential Eight will not see this.
  • An agent register is not a control any product ships with.
  • The gap is in what you know, not in what you have bought.

Where to start

Build the register first, because every other control depends on knowing what exists. Start with the field nobody has: the tools and data each agent can reach today.

That list is usually longer than expected, and shortening it is ISM-2156 and ISM-2157 in one piece of work. An agent security review produces that inventory. The Essential Eight assessment page sets out what that obligation covers, and this sits outside it. The rest is in the guides index.

The source

All eight controls above were read from the Information security manual, September 2026 release, published by the Australian Signals Directorate. Verified on 18 September 2026. The changes document for the same release states which controls were introduced and which were amended.

Instant quote

Get an instant quote in 2 minutes

Answer four questions. The indicative price updates as you go. Prices are ex GST.

Indicative until we confirm scope in writing, within one business day. We use your details only to reply. See our Privacy notice.

Questions before you book

Practical answers.

Which ISM release introduced the AI agent controls?

The September 2026 release of the Information security manual. It introduced 44 new controls in total, of which 7 concern AI agents directly. ISM-2113, which already existed, was amended in the same release.

Do the AI agent controls map to the Essential Eight?

No. All eight carry Essential 8: N/A in the source, and none of the 44 controls added in this release carries a maturity level. An organisation can meet Essential Eight Maturity Level Three and still not know how many agents it runs.

What has to be in an AI agent register?

ISM-2135 names five things per agent. The unique identifier. The owner and business purpose. The identities assigned to it. Any user accounts and credentials it uses. And the tools, permissions and data repositories it can access. That last field is the one most organisations cannot produce, because it is a property of configuration rather than of a document.

Does the ISM apply to a private company?

The ISM is written for government systems and binds a private company only where a framework or contract makes it so. It remains the most specific published statement of what good looks like here, and Australian buyers increasingly ask against it.

Can one service account be shared between agents?

Not under ISM-2133. Each agent needs an identity distinct from the user accounts of personnel and from the identities of other agents. A shared account fails on both counts, and makes the logging ISM-2159 asks for unattributable.

Let’s scope it

Do you know what your agents can reach?

Tell us where agents run and what they connect to. We will scope a review that produces the register the ISM asks for.

Request a quote