AI governance policy template for European organisations
For founders, operations, security, privacy, and AI leads drafting a proportionate policy people can use.
Start with a policy structure that connects principles to actual tools, owners, permitted uses, data handling, human review, incidents, and review dates.
A useful policy is a working starting point. This template is not an official EU form or a promise that a generated document is legally sufficient.
A reviewable starting point
- Start from how your organisation actually uses AI.
- Name the owner, evidence, and open question for each record.
- Keep the next review visible as tools and guidance change.
What to capture
What a usable policy should cover
The best policy is specific enough to guide a decision and connected enough to the underlying records that someone can review it.
- 01
Scope and purpose
Explain which teams, tools, features, and work activities the policy covers, and how it relates to the organisation’s existing security, privacy, and quality practices.
- 02
Decision rights and owners
Name who can approve a use, who owns a system, who reviews higher-risk questions, and who keeps the policy and its evidence current.
- 03
Data and vendor rules
Set practical expectations for data categories, confidential information, vendor accounts, access, retention questions, and procurement review.
- 04
Output review and human judgement
Describe when a person must check an output, what a reviewer should look for, and how the team records or corrects a consequential decision.
- 05
Incident escalation
Give people a clear route for reporting harmful, incorrect, exposed, or unexpected AI behaviour and define who coordinates the response.
- 06
Maintenance and evidence
Set an owner, review date, change history, and links to the inventory, approvals, training or literacy records, and supporting evidence.
Practical workflow
From inventory to policy to cadence
Draft the policy from the organisation’s actual AI use, then make review part of the operating rhythm.
- 01
Inventory
Use an AI inventory as the factual input: tools, purposes, owners, vendors, data categories, oversight, evidence, and open questions.
- 02
Draft
Turn those facts into a short policy with decision rights, allowed and restricted uses, review expectations, and an escalation path people can follow.
- 03
Review
Ask the appropriate privacy, security, legal, or operational reviewer to test the draft against the organisation’s context and set the next review date.
Scope and sources
A policy starter, not an official form
ProofCairn provides operational governance support, not legal advice or a definitive legal classification. Applicability depends on your role, system, use case, jurisdiction, and current guidance; professional review may be needed. The AI Act does not make this exact template universal, and using it does not establish ISO/IEC 42001 certification or legal sufficiency.
Questions worth asking
Keep uncertainty visible.
Is this an official EU AI Act policy template?
No. It is a practical structure for starting an internal policy. It is not issued by the European Union, does not decide which obligations apply, and should be adapted and reviewed for the organisation and systems involved.
Does the AI Act require every organisation to use this exact policy?
No. Whether and how requirements apply depends on the organisation’s role, the system, the use case, jurisdiction, and current guidance. Use authoritative sources and seek professional review where needed.
Where does AI literacy fit?
Treat literacy as an operational record: identify who needs awareness for the systems they use, what support is provided, and when it should be revisited. Consult the Commission’s Article 4 Q&A for current guidance; do not assume one universal certificate is required.
Five minutes to a clearer next step
Start with the free AI Governance Readiness Check.
Answer ten practical questions about how your organisation uses generative AI and get a prioritised operational signal.
Not legal advice, not a compliance test, and not a definitive legal classification.