AI Capability Maturity Assessment · Part II. The eight domains
Domain 2 · Foundations layerGovernance and operating model
In this chapter
Defines who is accountable, who decides and how AI use is overseen: owners, the governance committee, the register, the lines of assurance and decision rights.
What this domain covers
Defines who is accountable, who decides and how AI use is overseen: owners, the governance committee, the register, the lines of assurance and decision rights.
Governance turns strategy into decisions that stick. Named owners, a committee that decides rather than discusses, and a register that reflects reality are the minimum needed to answer the questions every auditor asks: what AI do you use, who is accountable for each use, and who decided it could proceed. Without them, controls exist on paper and nobody runs them.
Initiatives for this domain are run through the Governance and assurance and Operating model playbooks.
The domain at each level
A summary of what the domain looks like at each level. Each criterion below has its own descriptors and pass tests: score the criteria, not this summary. The domain score is calculated from them (see domain aggregation).
| Level | What it looks like |
|---|---|
| 1Initial | No accountable owners, register or governance forum. Nobody can list the AI in use or say who approved it. Decisions are made in projects or by email and cannot be traced. |
| 2Repeatable | Some owners are named and an informal list of AI projects exists. A working group meets but discusses rather than decides. Embedded vendor AI and staff use of general-purpose tools are missing from the list. Assurance happens when someone asks for it. |
| 3Defined | Every in-scope use case has a named accountable owner. A committee with terms of reference and decision rights meets at least monthly and keeps a decision log. The register is complete after a discovery sweep, including embedded AI. Three lines of assurance are assigned, and decision rights and escalation are written down. |
| 4Managed | The committee decides at gates on evidence, including refusals and conditions tracked to closure. The register is fed by intake and procurement, reconciled regularly and audited. Internal audit has completed an AI audit. Owners present their own submissions and attest annually. |
| 5Optimising | Governance is built into how work runs: decision rights are encoded in tooling, the register is a live system of record, standard decisions are delegated by rule, and the committee spends its time on exceptions and trends. Governance evidence feeds strategy and appetite. |
Risks when it is weak
- AI in use that nobody knows about, so it is never assessed
- Use cases with no accountable owner when something goes wrong
- A committee that becomes a talking shop and gates that become theatre
- Decisions that stall because two roles think they are accountable, or neither does
- Controls that exist technically but are never reviewed
The five criteria
| No. | Criterion | Importance | Scope |
|---|---|---|---|
| 2.1 | Accountable owners | Foundation | Enterprise arrangement, applied locally |
| 2.2 | AI governance committee | Foundation | Enterprise-level |
| 2.3 | Use-case register | Foundation | Enterprise arrangement, applied locally |
| 2.4 | Three lines of assurance | Enabling | Enterprise-level |
| 2.5 | Decision rights and escalation | Core | Enterprise arrangement, applied locally |
Criterion 2.1
Accountable owners
Accountability for AI is assigned to named people: an accountable executive or official for the AI program, and a single accountable owner for each AI use case, recorded centrally and kept current.
Why it matters
Accountability that belongs to a team, a vendor or a committee belongs to nobody. A single named owner per use case is the person who answers for its outcomes, makes sure its controls run, and decides when it should change or stop.
The five levels
| Level | What it looks like | To score this level |
|---|---|---|
| 1Initial | Nobody is recorded as accountable for AI use cases. Asked who owns one, interviewees name a team, a vendor or ‘IT’. | The starting point: no test. |
| 2Repeatable | Owners are named for some prominent use cases, often the project manager rather than a business executive. Ownership is not recorded centrally and lapses when people move. | At least one AI use case has a named owner on record. |
| 3Defined | Every in-scope use case on the register names one accountable owner of appropriate seniority. Owners have been briefed and have acknowledged the role in writing, and changes of owner are recorded within 30 days. | Every in-scope register entry names one owner, and written acknowledgements exist for a sample of five owners. |
| 4Managed | Owners perform the role: they present their own gate submissions, sign off reviews and attest annually. Ownership gaps (for example when an owner leaves) are detected and fixed within a defined time. | Owners presented their own gate submissions in the last 12 months, annual attestations are complete, and the process for detecting ownership gaps has been used. |
| 5Optimising | Ownership is written into position descriptions and performance agreements for business leaders, and owners retire or reshape their use cases on monitoring evidence without being prompted. | Owner accountabilities appear in position descriptions, and at least one owner-initiated retirement or reshape is recorded. |
Evidence to request
Documents
- Designation or appointment records
- Owner role description and briefing material
Records of it operating
- Register owner field
- Owner acknowledgements
- Annual owner attestations
- Owner change log
In systems
- Link between the leaver process and the register (optional)
In the evidence request: ER-2-01.
Interview probes
- Use-case owner or business leadDid you know you are the accountable owner for this use case? What does that require of you?
- Executive sponsor or Chief AI OfficerWho is accountable for AI overall, and who would answer to an inquiry about a specific use?
- Risk, compliance and internal auditWhat happens to ownership of a use case when its owner leaves?
Staff survey items: S04 I know who to ask for a decision about using AI in my work.
Red flags
- The owner on record is a vendor or a committee
- Owners are unaware that they are owners
- One person owns most of the use cases
Standards crosswalk
- ISO/IEC 42001
- Clause 5.3Annex A.3
- EU AI Act
- Article 26
- NIST AI RMF
- GOVERN 2
Government and organisation editions
Australian Government edition
In this edition the criterion readsAccountable officials for implementing the Policy are designated and the DTA is told of changes, and each in-scope AI use case has a single accountable use-case owner, recorded on the register and kept current.
Under Policy v2.0, accountable officials answer for implementing the policy and sit in the strategic layer. By 15 December 2026, each in-scope use case needs an accountable use-case owner.
Dated obligations
- 15 December 2026Accountable use-case owner for each in-scope use case (Policy v2.0)Met at level 3 (Defined) or higher
References
- Policy for the responsible use of AI in government, version 2.0Accountable officials; accountable use-case owner for each in-scope use case by 15 December 2026
Organisation edition
ISO/IEC 42001 requires roles and responsibilities for AI to be defined and allocated. The Guidance for AI Adoption starts with deciding who is accountable. Under the EU AI Act, deployers of high-risk systems must assign human oversight to people with the necessary competence and authority.
References
- ISO/IEC 42001:2023 Information technology - Artificial intelligence - Management systemClause 5.3; Annex A.3
- Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1GOVERN 2
- Guidance for AI AdoptionDecide who is accountable
- Voluntary AI Safety StandardGuardrail 1
- Regulation (EU) 2024/1689 (Artificial Intelligence Act), as amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI)Article 26, deployers of high-risk systems
In Governing Intelligence
In the AI governance assessment: Our accountable officials and Chief AI Officer are named, empowered and known to the DTA, and each in-scope use case has an accountable owner.
Initiatives that lift it
Criterion 2.2
AI governance committee
A governance body with terms of reference, cross-functional membership and decision rights decides on AI use cases, risk tiers, gates, approved tools and exceptions, and keeps a decision log.
Why it matters
Cross-functional decisions need a forum that can make them. Without one, security, privacy, legal and business views are collected one by one, conflicts are never resolved, and decisions are made by whoever is most persistent.
The five levels
| Level | What it looks like | To score this level |
|---|---|---|
| 1Initial | No forum governs AI. Decisions about AI use are made within project teams, by individual managers or by email. | The starting point: no test. |
| 2Repeatable | A working group or community of practice meets, but it discusses rather than decides: no terms of reference with decision rights, irregular attendance and no decision log. | Agendas or notes from at least two meetings of an AI working group in the last six months. |
| 3Defined | A committee operates under endorsed terms of reference with named decision rights, membership that includes security, privacy, legal, data, risk and business areas, a quorum rule, at least a monthly cadence and a decision log. | Endorsed terms of reference with decision rights, minutes of at least three meetings in the last six months, and a decision log. |
| 4Managed | The decision log shows the committee deciding at gates on evidence, including conditional approvals and refusals. Conditions are tracked to closure, and attendance and decision turnaround are measured. | The decision log includes conditional approvals or refusals that reference evidence, conditions are tracked to closure, and decision turnaround is measured. |
| 5Optimising | Standard decisions are delegated by clear rules, so the committee spends most of its time on exceptions and trends. It reviews its own effectiveness each year and changes how it works as a result. | A documented annual effectiveness review with changes made, and written delegation rules for standard decisions. |
Evidence to request
Documents
- Terms of reference
- Membership list
- Delegation rules for standard decisions
Records of it operating
- Agendas, papers and minutes for the last six months
- Decision log
- Conditions tracker
- Effectiveness review
In the evidence request: ER-2-02.
Interview probes
- Executive sponsor or Chief AI OfficerWhat has the committee refused or approved with conditions, and why?
- Legal, privacy and records leadDo you attend, and do you receive papers early enough to give real advice?
- Use-case owner or business leadHow long did it take to get a decision on your use case, and was the decision clear?
Red flags
- The committee has never refused or conditioned anything
- Terms of reference exist but contain no decision rights
- Quorum is rarely met, or decisions appear in minutes but not in the log
Standards crosswalk
- ISO/IEC 42001
- Clause 5.1Clause 5.3Annex A.3
- EU AI Act
- No direct mapping
- NIST AI RMF
- GOVERN 2
Government and organisation editions
Australian Government edition
Policy v2.0 expects AI incident processes to be overseen by a governance body by 15 December 2026 and high-risk use cases to be governed through a board or senior executive; the committee is the natural home for both. The ANAO’s criteria look for enterprise-wide accountabilities.
References
- Policy for the responsible use of AI in government, version 2.0AI incident processes overseen by a governance body; high-risk use cases
- Auditor-General Report No. 26 2024-25: Governance of Artificial Intelligence at the Australian Taxation OfficeEnterprise-wide accountabilities
Organisation edition
ISO/IEC 42001 requires leadership commitment and assigned authorities for the AI management system; a committee with decision rights is the usual way to provide both.
References
In Governing Intelligence
In the AI governance assessment: Our AI Governance Committee meets, and its minutes show decisions.
Initiatives that lift it
Criterion 2.3
Use-case register
A register records every AI use case, including AI embedded in purchased products and staff use of general-purpose tools, with owner, purpose, tier, lifecycle stage and assessment status, and periodic discovery keeps it current.
Why it matters
Nothing can be governed that is not known about. Obligations attach to AI use however it was acquired, and an auditor will not distinguish between AI the organisation chose and AI it absorbed through a product update.
The five levels
| Level | What it looks like | To score this level |
|---|---|---|
| 1Initial | There is no register of AI use. Nobody in the organisation can produce a list of the AI currently in use. | The starting point: no test. |
| 2Repeatable | A list exists, often a spreadsheet of projects, covering deliberate projects only. Embedded vendor AI and staff use of general-purpose tools are absent, and fields and currency vary. | A list of AI projects or tools can be produced. |
| 3Defined | A register with defined fields (owner, purpose, tier, stage, assessment status, data used, vendor) covers deliberate and embedded AI. A discovery sweep of procurement, software features, analytics teams and staff use has been run in the last 12 months and its findings added. | The register can be exported with all defined fields populated for at least 90 percent of entries, and a discovery sweep record from the last 12 months shows embedded AI was searched for. |
| 4Managed | Intake and procurement processes create register entries, so new AI cannot be adopted without one. Discovery runs at least twice a year, the register is reconciled with procurement records and the approved tool list, and variances are resolved. | Evidence that intake or procurement creates register entries, and a reconciliation in the last six months with its variances resolved. |
| 5Optimising | The register is a live system of record linked to runtime telemetry: agents and automations register themselves, inactive entries are flagged, and the register produces the transparency statement and review schedule without manual compilation. | Register entries are created and updated from runtime systems, and the transparency statement or review schedule is generated from the register. |
Evidence to request
Documents
- Register field definitions
- Discovery sweep method
Records of it operating
- Register export
- Discovery sweep results
- Reconciliation records against procurement and the approved tool list
In systems
- Intake or procurement workflow that creates register entries
- Runtime registration of agents and automations
In the evidence request: ER-2-03.
Interview probes
- CIO or CTOIf a vendor switched on an AI feature inside a product you already use, how would it get onto the register?
- Chief Data Officer or data ownerWhich analytics or machine learning models are in operational use, and are they all on the register?
- Frontline staffWhich AI tools do you use for work, including features built into other software?
Red flags
- The register count is far below the tool use staff report in the survey
- There are no entries for AI embedded in purchased products
- The register has not been updated for more than six months
Standards crosswalk
- ISO/IEC 42001
- Annex A.4Annex A.6
- EU AI Act
- Article 49
- NIST AI RMF
- GOVERN 1
Government and organisation editions
Australian Government edition
Policy v2.0 requires an internal register of in-scope AI use cases, owners, assessments and mitigations by 15 December 2026, shared with the DTA every six months. The ISM added controls for an AI agent register in September 2026.
Dated obligations
- 15 December 2026Internal register of in-scope AI use cases (Policy v2.0)Met at level 3 (Defined) or higher
References
- Policy for the responsible use of AI in government, version 2.0Internal register of in-scope use cases, shared with the DTA every six months
- Information Security ManualAI agent register (September 2026)
Organisation edition
The NIST AI RMF expects mechanisms to inventory AI systems. ISO/IEC 42001 requires AI system resources and life cycles to be documented. Providers and certain deployers of high-risk systems in the EU must register them in the EU database.
References
- Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1GOVERN 1 (inventory of AI systems)
- ISO/IEC 42001:2023 Information technology - Artificial intelligence - Management systemAnnex A.4 and A.6
- Regulation (EU) 2024/1689 (Artificial Intelligence Act), as amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI)Article 49 registration, high-risk systems only
In Governing Intelligence
In the AI governance assessment: Our register is complete, including discovered and embedded AI.
Initiatives that lift it
Criterion 2.4
Three lines of assurance
Three lines of assurance are assigned for AI: business owners operate the controls, risk, privacy and security functions oversee them, and internal audit assures them independently.
Why it matters
Controls that are never independently tested drift into controls that exist only on paper. Clear lines also stop oversight functions from doing first-line work, which leaves nobody independent.
The five levels
| Level | What it looks like | To score this level |
|---|---|---|
| 1Initial | Nobody is assigned to assure AI use, no oversight function reviews it, and internal audit has not considered it. | The starting point: no test. |
| 2Repeatable | Second-line functions review some AI projects on request. Internal audit has noted AI as an emerging risk but has no planned AI work. | At least one second-line review of an AI project can be produced. |
| 3Defined | An assurance map assigns AI responsibilities to each line with named functions. Second-line review is built into the lifecycle, and AI appears in the internal audit plan within the next 18 months. | An assurance map naming the function for each line, and an internal audit plan that includes AI within 18 months. |
| 4Managed | Internal audit has completed at least one AI audit with findings tracked to closure, and second-line functions test that first-line controls operate, not just that they exist. | A completed internal AI audit report with findings tracked to closure, and at least one second-line control test record. |
| 5Optimising | Assurance is continuous: second-line monitoring uses runtime evidence, combined assurance reports go to the audit and risk committee, and audit findings change the framework itself. | A combined assurance report using runtime evidence, and a framework change traced to an audit finding. |
Evidence to request
Documents
- AI assurance map
- Internal audit plan
Records of it operating
- AI audit report and findings tracker
- Second-line control test records
- Audit and risk committee papers on AI
In the evidence request: ER-2-04.
Interview probes
- Risk, compliance and internal auditWhen will internal audit next look at AI, and against what criteria?
- CISO or security leadWhich AI controls do you test yourselves, and which do you rely on the owner for?
- Executive sponsor or Chief AI OfficerWhat has the audit and risk committee asked about AI in the last year?
Red flags
- The second line does the first line’s work, so nobody is independent
- The internal audit plan is silent on AI
- Audit reviewed the policy but never tested whether controls operate
Standards crosswalk
- ISO/IEC 42001
- Clause 9.2
- EU AI Act
- No direct mapping
- NIST AI RMF
- GOVERN 1GOVERN 4
Government and organisation editions
Australian Government edition
The ANAO now audits AI governance directly. Its audit of the ATO found arrangements only partly effective; its audit of IP Australia found a largely effective agency and still recommended stronger AI cyber-security governance and risk-based monitoring. Internal audit should test against the same criteria first.
References
Organisation edition
ISO/IEC 42001 requires internal audits of the AI management system. Prudentially regulated entities should align AI assurance with their operational risk obligations.
References
- ISO/IEC 42001:2023 Information technology - Artificial intelligence - Management systemClause 9.2 internal audit
- Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1GOVERN function
- Beware the gap: Governance arrangements in the face of AI innovation (ASIC Report 798)
- Prudential Standard CPS 230 Operational Risk ManagementOperational risk management, for APRA-regulated entities
In Governing Intelligence
In the AI governance assessment: The three lines of assurance are assigned for AI.
Initiatives that lift it
Criterion 2.5
Decision rights and escalation
Decision rights for AI are written down (who approves a use case, a tool, a model change or an exception), follow a single-owner rule, and an escalation path is defined and used.
Why it matters
Unclear decision rights produce two failures: decisions stall because nobody knows who decides, or they are made by the wrong person because nobody stopped them. Both are common in AI, where decisions cut across technology, risk and business lines.
The five levels
| Level | What it looks like | To score this level |
|---|---|---|
| 1Initial | Nobody can say who approves a new AI use or tool. Decisions are made by whoever holds the budget. | The starting point: no test. |
| 2Repeatable | Some decisions are clear (for example IT approves software), but AI-specific decisions such as tiering, model changes and exceptions have no owner, so they stall or bypass review. | At least some AI decisions have a documented approver. |
| 3Defined | A RACI covers the main AI decisions with one accountable role each. Decision categories (standard, use case, platform, strategic) are defined with who decides and indicative turnaround, and the escalation path is documented. | A RACI with a single accountable role per decision, and documented decision categories with an escalation path. |
| 4Managed | Escalations are logged with outcome and time taken. The RACI is tested against real cases at least annually, and standard decisions are delegated so the committee sees only what needs it. | An escalation log for the last 12 months (or a record that none occurred) and an annual test of the RACI against real cases. |
| 5Optimising | Decision rights are encoded in tooling (approval routing, autonomy settings, policy checks) so the right person is asked automatically, and changes to decision rights follow a controlled process. | Approval routing or autonomy configuration in tooling that implements the RACI, with a change record. |
Evidence to request
Documents
- AI RACI
- Decision categories and turnaround
- Escalation path
Records of it operating
- Escalation log
- Worked examples or RACI test record
In systems
- Approval routing configuration in workflow or agent platforms
In the evidence request: ER-2-05.
Interview probes
- Use-case owner or business leadWho approved your use case, and who would approve a change to its model?
- CIO or CTOWalk me through what happens when a vendor switches on a new AI feature.
- Risk, compliance and internal auditShow me an escalation from the last six months and how it was resolved.
Staff survey items: S04 I know who to ask for a decision about using AI in my work.
Red flags
- Two roles are accountable for the same decision
- Escalation happens only through personal relationships
- Exceptions are approved by the requester’s own manager
Standards crosswalk
- ISO/IEC 42001
- Clause 5.3Annex A.3
- EU AI Act
- No direct mapping
- NIST AI RMF
- GOVERN 2
Government and organisation editions
Australian Government edition
Clear decision rights are how an agency shows the ANAO enterprise-wide accountabilities, and how high-risk uses reach the board or senior executive that Policy v2.0 requires to govern them.
References
- Policy for the responsible use of AI in government, version 2.0High-risk use cases
- Auditor-General Report No. 26 2024-25: Governance of Artificial Intelligence at the Australian Taxation OfficeEnterprise-wide accountabilities
Organisation edition
ISO/IEC 42001 requires responsibilities and authorities for AI to be assigned and communicated.
References
- ISO/IEC 42001:2023 Information technology - Artificial intelligence - Management systemClause 5.3; Annex A.3
- Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1GOVERN 2
- Guidance for AI AdoptionDecide who is accountable
In Governing Intelligence
- 6.2Accountable officials and decision rights
- Appendix CAI governance RACI and committee terms of reference
Initiatives that lift it
In Governing Intelligence
The framework chapters that describe the practice this domain measures, and the governance assessment questions that test it at a higher level.
- 6.1Four layers of accountability
- 6.2Accountable officials and decision rights
- 6.3The AI Governance Committee
- 6.4Three lines of assurance
- Appendix CAI governance RACI and committee terms of reference
In the AI governance assessment: Our accountable officials and Chief AI Officer are named, empowered and known to the DTA, and each in-scope use case has an accountable owner.
Our AI Governance Committee meets, and its minutes show decisions.
Our register is complete, including discovered and embedded AI.
The three lines of assurance are assigned for AI.
This assessment is not legal advice and is not a certification. Obligations and dates were checked against official sources on 15 October 2026; confirm them against the source instruments, which can change.