Responsible AI Platform
Governance Guide 2025

AI Governance

From policy to operational control

From risk management to supervisors, from documentation requirements to audit preparation. The complete guide to setting up and managing AI governance in your organization.

3 Lines
Defense
DPIA
& FRIA
Audit
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~15 min readLast updated: December 2025
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What is AI Governance?

The foundation for responsible AI use

AI Governance is the set of policies, processes, roles and controls by which an organization manages its AI systems. 2025 marks a turning point: from experimental frameworks to operational compliance. Organizations face the challenge of turning compliance frameworks into working governance structures. The goal is not only to manage risks, but also to build trust with stakeholders and create value through reliable AI.

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Policy & Principles

Clear guidelines for responsible AI use.

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Roles & Responsibilities

Clear ownership for each AI use case.

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Processes

Standardized workflows for lifecycle management.

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Controls

Testable measures to manage risks.

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Governance Structure

The three lines model for AI

Effective AI governance follows the three lines model. The first line consists of operational ownership: a product owner for each AI use case, development teams and business owners. The second line forms independent control: risk management, compliance and legal. The third line is internal audit that periodically assesses whether governance works effectively. C-level sponsorship through an AI Ethics Board or Chief AI Officer provides strategic direction.

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First line

Operational ownership and daily management.

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Second line

Independent risk, compliance and legal functions.

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Third line

Internal audit for periodic assessment.

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C-level

AI Ethics Board or Chief AI Officer.

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Risk Management

Continuous identification and mitigation

The NIST AI Risk Management Framework provides a practical starting point with four functions: Govern, Map (identify and understand risks), Measure (measure and evaluate) and Manage (manage and mitigate). This cyclical approach ensures continuous attention to risks throughout the AI lifecycle. Effective risk management goes beyond technical metrics and also includes bias, fairness, privacy and security.

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Map

Identify risks, stakeholders and impact.

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Measure

Evaluate risks with metrics and thresholds.

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Manage

Implement mitigation measures.

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Continuous cycle

Periodic reassessment and improvement.

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Documentation Requirements

If it is not documented, it does not exist

The EU AI Act requires comprehensive documentation for high-risk AI systems. This includes technical documentation about the model, training data provenance, evaluation results and known limitations. An AI register forms the basis: per system name, purpose, risk classification, responsible party, data sources, model version and monitoring metrics. Model Cards and AI Bill of Materials are practical formats to structure this.

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Technical documentation

Model architecture, training, evaluation.

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AI register

Central inventory of all AI systems.

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Model Card

Standardized model documentation.

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Audit trail

Decision-making and change history.

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Impact Assessments

DPIA, FRIA and more

Different assessments are required depending on the type of AI system. A DPIA (Data Protection Impact Assessment) focuses on privacy risks and is mandatory under GDPR. A FRIA (Fundamental Rights Impact Assessment) is broader and assesses impact on all fundamental rights, mandatory for high-risk deployers under the EU AI Act. Additionally, there are conformity assessments that providers must conduct for high-risk systems.

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DPIA

Privacy impact assessment under GDPR.

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FRIA

Fundamental rights impact assessment.

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Conformity assessment

For high-risk systems on the EU market.

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Periodic review

Annual reassessment of assessments.

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Supervisors

Who supervises and what do they expect?

Enforcement is coordinated by the European AI Office at EU level and national supervisors in each member state. In the Netherlands these are the Data Protection Authority for privacy aspects and the Algorithm Supervisor for algorithmic systems. Sectoral supervisors such as AFM and DNB also have AI in their mandate. Incident reporting is mandatory within 15 days for serious malfunctions.

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EU AI Office

European coordination and GPAI oversight.

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National supervisors

DPA, Algorithm Supervisor, sectoral authorities.

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Incident reporting

Reporting obligation within 15 days for serious malfunctions.

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Sanctions

Up to €35M or 7% global turnover.

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Audit Readiness

Being prepared for oversight

Audit readiness means your organization can demonstrate at any time that AI governance works effectively. This requires complete documentation, real-time monitoring dashboards, clear escalation paths and trained personnel. Conduct regular internal audits to identify gaps before external supervisors arrive. A mock audit helps test the maturity of your governance.

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Documentation complete

All required documents up-to-date and accessible.

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Monitoring dashboards

Real-time insight into compliance status.

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Trained personnel

Staff know procedures and responsibilities.

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Mock audits

Periodic internal tests of governance effectiveness.

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Tools & Templates

Practical resources

Various tools and templates are available to support AI governance. Microsoft's Responsible AI Impact Assessment template provides a practical format for impact assessments. The Dutch Algorithm Register shows how you can document AI transparently. ISO/IEC 42001 provides a formal structure for an AI management system. Standard formats for Model Cards and AI Bill of Materials help with consistent documentation.

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Impact Assessment Templates

Microsoft RAI, ALTAI and other formats.

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Algorithm Register

Dutch government as example.

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ISO/IEC 42001

Formal AI management system.

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Model Cards

Standardized model documentation.

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Frequently Asked Questions

Answers to the most common questions about AI Governance

What exactly is AI Governance?↓

AI Governance is the set of policies, processes, roles and controls by which an organization manages its AI systems. It includes risk management, compliance, ethical guidelines, documentation and oversight. The goal is to deploy AI in a responsible, transparent and compliant manner.

What governance structure do I need for AI?↓

An effective AI governance structure follows the 'three lines model': first line (operational ownership per AI use case), second line (independent risk and compliance functions) and third line (internal audit). C-level sponsorship is also essential, often through an AI Ethics Board or Chief AI Officer.

What is the difference between DPIA and FRIA?↓

A DPIA (Data Protection Impact Assessment) focuses on privacy risks in processing personal data, mandatory under GDPR. A FRIA (Fundamental Rights Impact Assessment) is broader and assesses impact on all fundamental rights, mandatory under the EU AI Act for high-risk deployers. Often both are conducted together.

How do I prepare for an AI audit?↓

Ensure complete documentation: AI inventory, risk assessments, technical documentation, training records, incident logs and decision-making processes. Implement monitoring dashboards for real-time compliance status. Conduct internal audits to identify gaps before external supervisors arrive.

Who are the AI supervisors in the EU?↓

Each member state designates national supervisors. At EU level, the European AI Office coordinates enforcement. Sectoral supervisors (financial, healthcare) also have AI in their mandate. Data protection authorities oversee AI and privacy intersection.

What should be in my AI register?↓

An AI register contains per system: name and description, purpose and legal basis, risk classification, responsible owner, data used and sources, model type and version, deployment date, monitoring metrics and last review date. This forms the basis for all governance activities.

How often should I review AI systems?↓

High-risk systems: at least annual formal review, plus continuous monitoring. Limited risk: annual review usually sufficient. Minimal risk: biannually or on significant changes. For incidents, model updates or regulatory changes: always ad-hoc review.

What are the costs of poor AI governance?↓

Direct costs: fines up to €35M or 7% turnover, redesign costs, incident response. Indirect costs: reputational damage (average 15% revenue decline), talent loss (30% higher turnover), delayed time-to-market. Proactive governance costs 5-10% upfront but saves 30-50% on reactive corrections.

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