Enterprise AI Governance Policy Template

Disclaimer

This template is provided for educational and planning purposes only. It is not legal, regulatory, compliance, audit, security, privacy, or professional advice. Organizations should review and adapt this document with their legal, compliance, security, privacy, risk, audit, business, and executive teams before use.

1. Purpose

This policy establishes governance, accountability, oversight, risk management, security, monitoring, evidence, and review requirements for AI systems, generative AI tools, and autonomous AI agents used by the organization.

2. Scope

This policy applies to AI systems, generative AI tools, large language models, AI assistants, autonomous agents, agentic workflows, internal tools, third-party AI services, vendors, contractors, employees, and customer-facing AI use cases.

3. Definitions

Term	Definition
AI System	A software, model, tool, workflow, or service that uses artificial intelligence to generate, classify, recommend, automate, predict, summarize, retrieve, transform, or support decisions.
AI Agent	An AI-enabled system that can pursue assigned objectives, use tools, call APIs, access data, interact with systems, or coordinate workflow steps.
Autonomous Action	An action performed by an AI system or AI agent without immediate human approval at the moment of action.
Human Reviewer	A designated person responsible for reviewing, approving, denying, escalating, or requesting more evidence for AI-related work.
Agent Owner	The accountable human owner responsible for an AI agent's purpose, scope, risk tier, permissions, review path, and lifecycle.
Agent Passport	A governance record for an AI agent's identity, owner, purpose, approved scope, data access, tools, actions, review requirements, evidence, and lifecycle state.
Agent Registry	The organization's inventory of AI systems and AI agents, including owner, purpose, risk, permissions, review state, and lifecycle status.
Runtime Authorization	A scoped authorization decision that determines whether a specific AI action may proceed under current policy, evidence, approval, and runtime state.
Human-in-the-Loop	A control pattern requiring a human reviewer to review, approve, deny, or escalate AI-generated work before it creates impact.
Evidence Record	A record that supports a governance decision, such as an approval, denial, action log, exception, incident, review, or audit-supporting artifact.
High-Risk AI Use Case	A use case that may materially affect people, finances, legal rights, regulated obligations, security posture, operations, customer outcomes, or critical systems.
Third-Party AI Service	An AI system, model, platform, API, tool, or service provided by an external party.

4. Governance Roles and Responsibilities

Role	Named Owner	Responsibilities
Executive Sponsor	________	Sets AI governance expectations, approves program direction, and resolves executive-level risk decisions.
AI Governance Committee	________	Reviews AI governance standards, high-risk use cases, exceptions, lifecycle reviews, and policy updates.
Business Owner	________	Owns business purpose, value, process fit, and operational acceptance.
Agent Owner	________	Owns agent purpose, scope, Passport, risk tier, permissions, evidence, and lifecycle.
Product Owner	________	Owns user needs, roadmap fit, release readiness, and user-facing controls.
Security Reviewer	________	Reviews identity, access, secrets, network, tool/API, logging, monitoring, and incident controls.
Compliance Reviewer	________	Reviews regulatory obligations, policy mapping, evidence needs, and review requirements.
Privacy Reviewer	________	Reviews personal data, sensitive data, retention, sharing, and privacy impact.
Human Reviewer	________	Reviews outputs, approvals, exceptions, escalations, and high-risk recommendations.
Platform Operator	________	Operates platform controls, logging, monitoring, and approved runtime changes.
Internal Audit	________	Reviews evidence completeness and control operation when audit review is in scope.

5. AI Inventory and Registration Requirements

All AI systems and AI agents must be registered before production use.

Field	Value
AI system or agent name	________
Business purpose	________
Owner	________
Department	________
Risk level	Level __
Data classification	________
Model/provider used	________
Tools/connectors used	________
Permissions	________
Human oversight requirement	________
Expiration/review date	________
Approval status	Draft / Under Review / Approved for Test / Approved for Production / Suspended / Retired

6. Agent Passport Requirements

Production AI agents should have an approved Agent Passport before use in organization workflows.

Field	Value
Agent Passport ID	________
Agent name	________
Agent version	________
Owner	________
Approved purpose	________
Approved data access	________
Approved tools	________
Approved actions	________
Runtime boundaries	________
Human approval requirements	________
Evidence/logging requirements	________
Expiration date	________
Reviewers and approvers	________

7. Risk Classification

Level	Description	Minimum Approval Requirement
Level 1	Informational / low risk	Business owner review.
Level 2	Internal productivity	Business owner and security/privacy screening.
Level 3	Business process support	Business owner, agent owner, security reviewer, and human oversight plan.
Level 4	High-impact decision support	AI governance committee review, compliance/privacy review, evidence plan, monitoring plan, and human approval path.
Level 5	Regulated, critical, or autonomous action	Executive sponsor approval, legal/compliance/security/privacy review, explicit runtime authorization, human review path, audit evidence plan, and lifecycle review.

8. Human Accountability

Accountability remains with designated human owners and reviewers regardless of automation level. AI systems and agents may draft, classify, summarize, recommend, route, prepare evidence, or support decisions. They must not approve their own work, expand their own authority, bypass review, or take high-risk action without an approved human review path.

9. Runtime Authorization

Permitted and restricted action types must be defined before use.

Action Type	Allowed?	Approval Required?	Notes
Read	Yes / No	Yes / No	________
Create	Yes / No	Yes / No	________
Update	Yes / No	Yes / No	________
Delete	Yes / No	Yes / No	________
Execute	Yes / No	Yes / No	________
Communicate externally	Yes / No	Yes / No	________
Trigger workflow	Yes / No	Yes / No	________
Access sensitive data	Yes / No	Yes / No	________
Make recommendations	Yes / No	Yes / No	________
Take autonomous action	Yes / No	Yes / No	________

High-risk actions should require explicit approval and current authorization before execution.

10. Human-in-the-Loop Requirements

Human review is required when AI work involves sensitive data access, financial action, legal or regulatory action, employment-related decision support, customer-impacting decision support, external communication, high-risk recommendation, exception handling, or material system, workflow, access, or deployment change.

11. Monitoring, Logging, and Evidence

The organization should maintain activity logs, tool usage logs, decision records, approval records, escalation records, exception records, audit-supporting evidence, and evidence retention for ________ years.

12. Security Requirements

AI systems and agents must follow organization security requirements, including identity and access management, least privilege, secrets management, Zero Trust principles, API security, encryption, data loss prevention, environment separation, incident response, and vendor security review.

13. Data Governance and Privacy

AI systems and agents must follow organization data governance and privacy requirements, including data classification, personal data handling, sensitive data handling, confidential data handling, training data restrictions, prompt/input restrictions, output handling, retention, data sharing, and cross-border concerns.

14. Third-Party AI and Vendor Requirements

Third-party AI services require review of vendor terms, data usage, security controls, privacy controls, model training terms, audit rights, regulatory obligations, and exit or termination considerations.

15. Scaled Agents Seven Layers of Agent Governance and Accountability

Agent Identity and Registration.
Agent Design and Accountability.
Runtime Authorization.
Execution Monitoring.
Human Oversight.
Compliance and Risk Management.
Audit and Evidence.

16. Framework Alignment

This policy may support alignment with NIST AI RMF, ISO/IEC 42001, ISO/IEC 27001, CSA AI Controls Matrix, EU AI Act, and organization-specific regulatory requirements. This template does not certify compliance with any framework, law, regulation, or standard.

17. Policy Violations

Examples include using unapproved AI tools, deploying unregistered agents, bypassing human approval, unauthorized data access, missing evidence logs, using third-party AI without review, or expanding agent permissions without approval.

18. Exceptions Process

Field	Value
Exception requested by	________
Business justification	________
Risk description	________
Compensating controls	________
Expiration date	________
Approver	________
Review date	________

19. Policy Review and Maintenance

Field	Value
Review cadence	________
Policy owner	________
Approval authority	________
Change history	________
Version history	________

20. Appendices

Appendix A: AI System Registration Form

Name: ________ Purpose: ________ Owner: ________ Risk level: ________ Data classification: ________ Approval status: ________

Appendix B: Agent Passport Intake Form

Agent name: ________ Owner: ________ Approved purpose: ________ Approved data access: ________ Approved tools/actions: ________ Human review requirements: ________ Evidence requirements: ________

Appendix C: AI Risk Assessment Worksheet

Use case: ________ Impact: ________ Data sensitivity: ________ Autonomy level: ________ Human oversight: ________ Risk tier: ________ Required controls: ________

Appendix D: Human Review Checklist

Owner identified. Risk level assigned. Evidence reviewed. Data access reviewed. Tool permissions reviewed. External communication reviewed. Approval, denial, or escalation recorded.

Appendix E: Third-Party AI Review Checklist

Terms reviewed. Data usage reviewed. Security controls reviewed. Privacy controls reviewed. Model training terms reviewed. Audit rights reviewed. Exit path reviewed.

Appendix F: AI Governance Committee Charter Placeholder

Purpose: ________ Membership: ________ Decision authority: ________ Meeting cadence: ________ Escalation path: ________

Appendix G: AI Incident Intake Form

Incident date: ________ Reported by: ________ AI system or agent: ________ Description: ________ Impact: ________ Immediate containment: ________ Owner: ________ Evidence references: ________

Enterprise AI Governance Policy Template

Use this as a starting policy, not as a final approval.

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