AcademySecure & Govern

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.

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S201Secure & Govern · Practitioner

AI Governance in Practice

Turning regulation and frameworks into a working governance system for AI.

FormatKnowledge pack · 14 slides
ForRisk, security and IT leaders
LevelPractitioner
Axiarete Academy · S20102 / 14

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.

InventoryEvery system, including features inside SaaS.
RiskHarm to people and the business, by tier.
AccountabilityWho decided, and on what basis.
AssuranceMonitoring, evaluation and periodic review.
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20103 / 14

Regulation

The EU AI Act regulates by risk

CategoryExamplesObligations
ProhibitedSocial scoring, manipulation, emotion recognition at workBanned since February 2025; two more bans from December 2026
High-riskAnnex III uses such as employment, credit and critical infrastructureRisk management, data governance, logging, human oversight, conformity assessment
TransparencyChatbots, and AI-generated or manipulated contentDisclosure and labeling
MinimalMost other uses, such as spam filtersVoluntary codes; AI literacy measures still apply
General-purpose modelsBroadly capable models, such as large language modelsDocumentation, copyright policy and training-content summary since August 2025; more for systemic-risk models
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20104 / 14

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.

1Aug 2024The Act enters into force.
2Feb 2025Prohibitions and AI literacy apply.
3Aug 2025General-purpose model duties apply; earlier models by August 2027.
4Aug 2026Transparency duties apply and enforcement begins.
5Dec 2026Bans on non-consensual sexual deepfakes and CSAM apply; earlier generators must mark outputs (Art. 50(2)).
6Dec 2027High-risk obligations for Annex III uses apply; earlier systems only if significantly redesigned.
7Aug 2028High-risk obligations for Annex I products apply.
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20105 / 14

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).

RoleWho it isCore obligations for high-risk systems
ProviderDevelops or commissions a system and places it on the market or puts it into service under its own name or trademarkQuality management system, risk management, data governance, technical documentation, logging, human-oversight design, conformity assessment, registration, post-market monitoring
DeployerUses a system under its own authorityUse 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
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20106 / 14

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.

ISO/IEC 42001A certifiable AI management system: policy, roles, risk and impact assessment, controls, internal audit and improvement. Published in 2023.
NIST AI RMFA voluntary framework in four functions: Govern, Map, Measure and Manage. Version 1.0 (2023), now under revision; Generative AI Profile (NIST AI 600-1), 2024.
Legal obligationsThe EU AI Act, sector regulation and data protection law; in the United States, state laws such as Colorado’s, challenged by the Justice Department and rewritten in 2026.
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20107 / 14

Intake

From use-case intake to periodic review

1RegisterPurpose, owner, model, data and users.
2ClassifyLegal category, provider or deployer role, and internal tier.
3AssessImpact, data, security and fairness, as the tier requires.
4DecideApprove, approve with conditions, or decline.
5DeployWith the controls the decision requires.
6MonitorPerformance, incidents and drift.
7ReviewOn every material change, and on a fixed cycle.
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20108 / 14

Tiering

Tier risk on factors you can assess

FactorLower riskHigher risk
Who is affectedStaff as users of assistive toolsCustomers, applicants, the public
Role in the decisionSuggests; a person decidesDetermines or materially shapes the outcome
AutonomyA person reviews every outputActs without review
DataPublic or internalPersonal or special-category data
ReversibilityEasily correctedHard to reverse once acted on
DomainNo sector rulesEmployment, credit, health, critical services
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20109 / 14

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.

Tier by actionSet the risk tier by the most consequential action the agent can take.
Bound in advanceApprove tools, data and spending limits with the use case, at the minimum necessary.
Accountable personEach agent traceable to a named person who answers for what it does.
Delegated authorityNever beyond the rights of the person or role it acts for.
CheckpointsHuman approval before significant or irreversible actions.
StopA tested way to interrupt it, as Art. 14(4)(e) requires for high-risk systems.
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20110 / 14

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.

Record for every system
  • 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
Require from suppliers
  • 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
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20111 / 14

Controls

Eight baseline controls

AI literacyTraining matched to how each role uses AI.
Approved toolsSanctioned options that reduce use of unapproved AI tools.
Human oversightDesigned into the workflow, with authority to stop.
TransparencyPeople are told when they are interacting with AI.
LoggingInputs, outputs and decisions; high-risk logs kept at least six months.
EvaluationOn representative cases, before release and on every material change.
Incident responseExisting processes extended to AI harms; Art. 73 reports due within 2, 10 or 15 days.
Security testingPrompt injection and data leakage tested and controlled.
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20112 / 14

Pitfalls

How AI governance goes wrong

Governing only what you build
Include SaaS features and purchased AI
Approval as a one-time event
Review on change and on a fixed cycle
Blocking every tool
Offer approved alternatives
Policy without an inventory
Start by knowing what is in use
Treating every use case as high risk
Tier, and spend effort where risk is real
Working apart from security and privacy
One intake, shared controls and evidence
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20113 / 14

Getting started

A 90-day plan

Days 1–30Foundations
  • Name an accountable executive and a cross-functional council
  • Publish acceptable use and approved tools
  • Start the inventory, including SaaS AI features
Days 31–60Process
  • Launch intake and risk tiering
  • Formalize role-based AI literacy (Art. 4)
  • Add AI clauses to supplier contracts
Days 61–90Assurance
  • Assess the highest-risk use cases first
  • Define monitoring and incident handling
  • Map gaps against ISO/IEC 42001 and the EU AI Act
AI Governance in PracticeSecure & Govern
Axiarete Academy · S20114 / 14

Summary

Key takeaways

  1. Governance is a continuous system: inventory, risk, accountability and assurance.
  2. Under the amended EU AI Act, Annex III high-risk obligations apply from December 2027.
  3. Know, system by system, whether you are a provider or a deployer.
  4. Use ISO/IEC 42001 for the management system and NIST AI RMF for risk methods.
  5. Hold purchased and embedded AI to the same intake, tiering and review.
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