An AI governance framework has to say who decides
Austin Wallis · Updated
Published guidance on AI governance now points to a small set of common references: the NIST AI Risk Management Framework (AI RMF 1.0), the ISO/IEC 42001:2023 standard for AI management systems, OMB memoranda M-25-21 and M-25-22 on federal agency AI use and acquisition, and guidance written for individual sectors. These documents set out what a governance program has to cover. The AI RMF, for example, calls for documented roles, responsibilities, and lines of communication (GOVERN 2.1). None of them can decide, for a particular organization, who holds which decision.
Those assignments are the harder part of the work. Who can approve a model for use in a critical system? Who has the authority to roll a model back when its performance drifts during operations? Which roles have to be defined before a capability moves from pilot to production? A framework people can follow answers each question in writing, naming the role that holds the decision and the point at which it escalates.
Decision-rights design for leadership teams is part of our AI governance practice.
Sources: NIST, Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1, January 2023 (GOVERN 2.1); ISO/IEC 42001:2023, Information technology — Artificial intelligence — Management system; OMB Memorandum M-25-21, Accelerating Federal Use of AI through Innovation, Governance, and Public Trust, April 2025; OMB Memorandum M-25-22, Driving Efficient Acquisition of Artificial Intelligence in Government, April 2025.