AI Governance in Practice
The EU AI Act after its 2026 amendments, NIST AI RMF and ISO/IEC 42001 combined into one system; use-case intake and risk tiering; the AI inventory; third-party, embedded and agentic AI; and eight baseline controls.
S201Practitioner·14 slides·About 13 minutes
S201Secure & Govern · Practitioner
AI Governance in Practice
Turning regulation and frameworks into a working governance system for AI.
The premise
AI governance as a continuous management system
Effective AI governance answers four questions continuously: what AI we use, what could go wrong, who decided it was acceptable, and how we know it still is.
Regulation
The EU AI Act regulates by risk
| Category | Examples | Obligations |
|---|---|---|
| Prohibited | Social scoring, manipulation, emotion recognition at work | Banned since February 2025; two more bans from December 2026 |
| High-risk | Annex III uses such as employment, credit and critical infrastructure | Risk management, data governance, logging, human oversight, conformity assessment |
| Transparency | Chatbots, and AI-generated or manipulated content | Disclosure and labeling |
| Minimal | Most other uses, such as spam filters | Voluntary codes; AI literacy measures still apply |
| General-purpose models | Broadly capable models, such as large language models | Documentation, copyright policy and training-content summary since August 2025; more for systemic-risk models |
Timeline
Key dates after the 2026 amendments
The Digital Omnibus on AI, Regulation (EU) 2026/1744, in force since July 27, 2026, deferred the high-risk dates, added two prohibitions and eased the AI literacy duty.
Roles
Your obligations depend on your role
Most enterprises are deployers. They become providers by building a system, by rebranding or substantially modifying a high-risk one, or by repurposing one into high-risk use (Art. 25).
| Role | Who it is | Core obligations for high-risk systems |
|---|---|---|
| Provider | Develops or commissions a system and places it on the market or puts it into service under its own name or trademark | Quality management system, risk management, data governance, technical documentation, logging, human-oversight design, conformity assessment, registration, post-market monitoring |
| Deployer | Uses a system under its own authority | Use it as instructed, assign competent oversight, check input data it controls, monitor and report incidents, keep logs at least six months, inform workers and affected people, assess fundamental-rights impact where Art. 27 applies |
Frameworks
How ISO/IEC 42001, NIST AI RMF and the law fit together
Use ISO/IEC 42001 for the management system, NIST AI RMF for risk methods and the law for obligations. ISO/IEC 42005 (2025) guides AI system impact assessment.
Intake
From use-case intake to periodic review
Tiering
Tier risk on factors you can assess
| Factor | Lower risk | Higher risk |
|---|---|---|
| Who is affected | Staff as users of assistive tools | Customers, applicants, the public |
| Role in the decision | Suggests; a person decides | Determines or materially shapes the outcome |
| Autonomy | A person reviews every output | Acts without review |
| Data | Public or internal | Personal or special-category data |
| Reversibility | Easily corrected | Hard to reverse once acted on |
| Domain | No sector rules | Employment, credit, health, critical services |
Agents
Govern agents by what they are allowed to do
Singapore’s Model AI Governance Framework for Agentic AI (January 2026) begins with two duties: assess and bound the risks upfront, and make humans meaningfully accountable.
Inventory and suppliers
Govern the AI you buy as rigorously as the AI you build
Many AI features arrive through updates to software you already license.
- Purpose, owner and users
- Provider, model and version
- Data used, and where it is processed
- Legal category, role and risk tier
- Controls, evaluations, incidents and next review
- No training on your data without consent
- Data residency and sub-processors
- Notice of material model changes
- Incident notice, cooperation and access to logs
- Settings to disable features you have not approved
Controls
Eight baseline controls
Pitfalls
How AI governance goes wrong
Getting started
A 90-day plan
- Name an accountable executive and a cross-functional council
- Publish acceptable use and approved tools
- Start the inventory, including SaaS AI features
- Launch intake and risk tiering
- Formalize role-based AI literacy (Art. 4)
- Add AI clauses to supplier contracts
- Assess the highest-risk use cases first
- Define monitoring and incident handling
- Map gaps against ISO/IEC 42001 and the EU AI Act
Summary
Key takeaways
- Governance is a continuous system: inventory, risk, accountability and assurance.
- Under the amended EU AI Act, Annex III high-risk obligations apply from December 2027.
- Know, system by system, whether you are a provider or a deployer.
- Use ISO/IEC 42001 for the management system and NIST AI RMF for risk methods.
- Hold purchased and embedded AI to the same intake, tiering and review.
Further reading
- AI Act implementation timeline (opens in a new tab)European Commission, AI Act Service Desk
- Digital Omnibus on AI: legislative train (opens in a new tab)European Parliament
- AI Risk Management Framework (opens in a new tab)NIST
- ISO/IEC 42001: AI management systems (opens in a new tab)ISO, 2023
- ISO/IEC 42005: AI system impact assessment (opens in a new tab)ISO, 2025
- Singapore launches new Model AI Governance Framework for Agentic AI (opens in a new tab)IMDA, January 2026
- Trust and AI governance at AxiareteAxiarete
Bring this course to your leadership team
We run private working sessions that apply these frameworks to your own estate, data and pending decisions.