Why Generic Frameworks Aren't Enough
Most organizations understand they need AI governance but don't know what it looks like in practice. Frameworks from NIST and ISO describe what a governance program must achieve — not how to build one. This page provides a concrete example of how an AI governance framework is structured, what documents it requires, and how to implement it.
The EU AI Act adds a new layer: organizations must now classify AI systems by risk tier and implement controls that match that classification. A governance framework is the mechanism that makes this possible.
What a Complete Framework Includes
- A top-level AI governance policy establishing scope, principles, and ownership
- An AI model inventory documenting every tool and model in production or evaluation
- A risk assessment process that classifies each AI use case by risk tier
- An acceptable use policy governing employee AI usage
- Vendor due diligence procedures for third-party AI tools
- Data classification and handling guidelines
- An incident response procedure for AI-related events
- EU AI Act system classification and compliance documentation
- A monitoring and review cycle — quarterly for high-risk, annual minimum
A framework that addresses SR 11-7, NIST AI RMF, and the EU AI Act together positions organizations to satisfy regulators across multiple jurisdictions with a single cohesive program.
What Causes Governance Frameworks to Fail
- Building a framework on paper without operational implementation
- Assigning governance to IT alone — it requires Legal, Risk, Compliance, and HR
- No board or senior management visibility — governance without executive accountability fails
- Treating the framework as static — it must evolve as AI tools and regulations change
- Ignoring low-risk AI tools — SR 11-7 requires inventory of all models
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