How to Write an AI Governance Policy: Step-by-Step Guide
A practical step-by-step guide to writing an organizational AI governance policy that is clear, enforceable, and adaptable.
Why AI Governance Policies Matter
An AI governance policy is the bridge between your organization's AI principles and day-to-day operations. Without a clear, enforceable policy, even well-intentioned AI teams may make inconsistent decisions about risk, compliance, and ethical considerations. A good policy provides clarity that enables faster, better decision-making rather than adding bureaucratic overhead.
The goal is not to create a document that sits in a binder. It is to create a practical reference that helps everyone in your organization understand their responsibilities when developing, deploying, and operating AI systems.
Before You Write: Preparation
Before drafting your policy, complete three preparatory steps.
First, inventory your AI systems. You cannot govern what you do not know about. Catalog every AI system in your organization, including its purpose, the data it uses, who it affects, and its current oversight mechanisms.
Second, identify your regulatory requirements. Map the regulations that apply to your AI use. This varies by industry, jurisdiction, and the type of AI applications you operate. Legal counsel should be involved in this mapping.
Third, engage stakeholders. A governance policy created in isolation will not be adopted. Involve AI practitioners, business leaders, legal and compliance teams, and where appropriate, representatives of communities affected by your AI systems.
Policy Structure
Organize your policy into clearly defined sections.
Scope and Applicability
Define exactly what the policy covers. Which AI systems? Which teams? Which types of decisions? Be specific about inclusions and exclusions. A policy with unclear scope will be applied inconsistently.Roles and Responsibilities
Define who is accountable for what. Common roles include AI system owners who are responsible for the behavior of specific AI systems, governance reviewers who assess AI systems against policy requirements, data stewards who ensure data used in AI systems meets quality and compliance requirements, and executive sponsors who provide organizational authority for governance decisions.Risk Classification
Define how AI systems are classified by risk level. Include clear criteria for each tier and the governance requirements associated with each level. A simple three-tier system of high, medium, and low risk works for most organizations.Development Requirements
Specify what must happen during AI system development, including training data documentation, bias testing, performance benchmarks, security assessment, and documentation standards.Deployment Requirements
Specify what must be completed before an AI system goes into production, including review and approval processes, testing requirements, monitoring setup, and rollback procedures.Ongoing Requirements
Specify ongoing obligations for production systems, including performance monitoring, fairness monitoring, regular review cycles, incident reporting, and documentation maintenance.Exception Process
No policy can anticipate every situation. Include a clear process for requesting exceptions, who can approve them, and how exceptions are documented.Writing Effective Policy Language
Write in clear, direct language that avoids ambiguity. Use must and shall for mandatory requirements, should for recommended practices, and may for optional guidance. Avoid vague language like appropriate measures or reasonable steps without defining what those mean in your context.
Include concrete examples where possible. A policy that says conduct bias testing before deployment is less useful than one that says conduct bias testing across protected characteristics including race, gender, age, and disability status using statistical parity and equalized odds metrics with thresholds defined in Appendix A.
Keep the policy as short as possible while being complete. Long policies are less likely to be read and followed. Move detailed procedures to appendices or supplementary documents.
Review and Approval
Before finalizing your policy, conduct a thorough review. Have legal counsel review for regulatory alignment. Have AI practitioners review for practical feasibility. Have business leaders review for operational impact. Have compliance teams review for consistency with other organizational policies.
Obtain formal approval from appropriate leadership. The level of approval needed depends on your organization, but policies that affect the entire organization typically require executive or board-level approval.
Implementation and Communication
A policy is only effective if people know about it and understand how to follow it. Create a communication plan that introduces the policy, explains its purpose, and describes what changes people should expect. Develop training materials that help AI practitioners understand the policy requirements and how to comply with them.
Make the policy easily accessible. If people cannot find the policy, they cannot follow it. Integrate policy requirements into existing workflows and tools rather than creating separate governance processes.
Keeping the Policy Current
Review your policy at least annually, or whenever significant changes occur in your regulatory environment, AI portfolio, or organizational structure. Track feedback from AI practitioners about what works and what creates unnecessary friction. Update the policy based on lessons learned from incidents, near-misses, and governance reviews.
ibl.ai's platform design supports governance policy implementation by providing organizations with full control over their AI systems and data. When you own the infrastructure, implementing and enforcing governance policies is a direct capability rather than a request to an external vendor. This ownership model, trusted by over 400 organizations worldwide, makes governance policies practical to implement and straightforward to verify.
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