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2027 AI Governance Checklist

Eighteen steps to prepare your organization for the AI laws and expectations arriving in 2027.

Prepared by the Cogent Assurance team

Checklist

Know your AI

  • List every AI tool and AI feature in use, including features vendors added to existing software
  • Name an owner for each AI use
  • Assign each use a risk tier

Set the rules

  • Adopt or update an AI acceptable use policy
  • Define which data may never be entered into AI tools
  • Set an approval process for new AI uses

Check your obligations

  • Confirm which state AI laws apply, including Colorado and California rules taking effect January 1, 2027
  • Review privacy notices for AI-related data sharing
  • Check industry rules such as HIPAA, fair lending, or FERPA

Control your vendors

  • Confirm vendors don’t train on your data
  • Add AI terms to contracts at renewal
  • Require notice before model changes

Test and prepare

  • Test high-risk AI systems before launch and after major changes
  • Add AI scenarios to your incident response plan
  • Run a tabletop exercise with leadership

Train and report

  • Train staff on your AI policy
  • Brief the board or leadership on AI risks
  • Schedule a review of this checklist each quarter

Need help working through the list? Our AI Governance Readiness Assessment covers every item.

This page is general information for planning purposes. Laws and guidance change, so confirm current requirements before acting. It is not legal advice. For legal advice about your organization, consult a licensed attorney.

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