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AI Governance

The Business Decides: The Rules Worth Following, and the Right People to Make Them

By Shawn Plaster, Founder & CEO, Plaster Group

Article 2 of 3 — Plaster Group’s AI Governance Methodology

CEOBoardCAIOGovernance BoardRisk Classification
·12 min read

Where Rules Come From Determines Whether They Hold

In the first article of this series we described the moment most organizations are actually in. AI is arriving along two legitimate tracks, a healthy decentralized wave of productivity tools and a deliberate centralized track that runs from bought point solutions to redesigned core workflows, and one governance discipline has to hold both. We also introduced the five-level methodology that answers this moment, every level behind a gate, from the decisions only leadership can make to the annual loop that keeps them honest. This article walks the first half of that methodology, Levels 1 through 3. We call it the deciding half. Its entire job is to get the right rules made by the right people and carried to the place where work is designed.

A useful thing to notice before we begin is that almost every organization already has pieces of this. An executive has been informally fielding AI questions. An AI policy possibly sits somewhere in legal. A security team has quietly set some sensible boundaries. None of that work is wasted, and none of it was wrong. What the methodology adds is arrangement. Each decision gets made once, at the right altitude, in writing, so that nobody downstream ever has to guess what the organization intended. When governance feels heavy, the usual culprit is decisions being remade over and over by people who were never given the authority to settle them. The deciding half exists to end that quietly exhausting cycle.

Level 1: The Decisions Only Leadership Can Make

Governance does not begin with committees or tools. It begins with five decisions taken in a deliberate order, each recorded in a short, signed artifact. Most fit on a single page. Every rule the program will ever create must trace back to a person with the authority to make it stick. Authority that is merely assumed is borrowed, and borrowed authority fails the first time it is tested.

  1. 01SponsorshipGovernance Sponsorship Memo
  2. 02Risk appetiteRisk Appetite and Tolerance Statement
  3. 03Hard linesProhibited and Restricted Use List
  4. 04Board oversightBoard Oversight Intent Note
  5. 05Operating structureOperating Structure Decision
The five Level 1 decisions in the order they are taken, each producing one signed artifact, from sponsorship through to the operating structure.Figure 2.1 · Level 1 Decision Chain · Plaster Group’s AI Governance Methodology · © 2026 Plaster Group

The order is part of the design, not a formality. The sponsor comes first so that the four decisions that follow have someone to convene them. The appetite precedes the hard lines, since boundaries calibrate to appetite. An organization cannot say what it will never do until it has said how much risk it is willing to carry and for what. The operating structure comes last, and deliberately so. It is the moment the sponsor’s solo authority gets its planned end date, and the structure decided there is what the sponsor has been holding the seat for. Executive teams that take these five in order find each decision easier than the one before it. Each arrives with its inputs already made.

The first decision creates a sponsor. The CEO names one executive to lead AI governance, and that executive accepts in writing. Until a governance body exists, someone must be able to answer the question every organization eventually faces. A team wants to deploy something new, so who says yes? One name, on one page, is the difference between a decision and a debate. The standards ask for exactly this, an executive who genuinely takes responsibility for AI risk decisions.1

The second sets the risk appetite. The CEO and executive team, with the CFO at the table, write down how much risk the organization will carry and for what. The statement uses tolerance bands specific enough that an engineer can build to them and a director can quote them, and the board of directors affirms it. Boards already know this discipline from enterprise risk. Management develops the appetite, and the board reviews and concurs.2 Everything downstream calibrates to this statement, from how systems are classified to where review thresholds sit to what the dashboards measure.

The third draws the hard lines. Leadership states what the organization will not do with AI, along with restricted uses that require a named approver, and counsel’s review goes on record. The test for every line is practical. Could someone write an automatic refusal rule from this sentence, as written? These few sentences later become exactly that, refusal rules built into the technology itself, word for word. Leaders write more carefully when they know their sentence will become software.

The fourth settles what the board of directors will see. The board chair or governance committee chair decides what directors review, how often, and through which committee, so oversight is designed on purpose rather than improvised after an incident. Many boards have yet to put AI anywhere on their agenda, roughly a third by Deloitte’s count, which makes this an easy decision to defer and an important one not to address.3 The same choice sets the path the AI policy will travel for ratification.

The fifth decides who runs governance day to day. The CEO decides the shape of the cross-functional governance board, its chair, its seats, and where its small permanent support team will live. Only the CEO can make this call. Every seat at that table is carved from some executive’s territory. The research gives the decision unusual weight. McKinsey finds CEO-level oversight of AI governance among the elements most strongly correlated with bottom-line impact from AI,4 and the international management standard for AI makes top-management ownership a requirement rather than a suggestion.5 With this decision made, Level 2 can begin.

Level 1 is short, inexpensive, and decisive. It requires no new technology and no reorganization, just leadership putting its name to the questions only leadership can answer. Many executive teams find it clarifying in a way that surprises them. A diffuse sense of shared responsibility becomes five specific commitments, each with a name attached.

Level 2: The Rulebook, Written as Architecture

With leadership’s decisions in hand, Level 2 writes the organization’s rulebook, and writes it as architecture. The result is a connected set of frameworks that everything downstream will apply but never have to re-decide.

One clarification is worth making before the walk. Two bodies in this methodology both get called “the board” in casual conversation. The board of directors is the fiduciary body the organization already has. In this methodology it affirms and ratifies, and the only decision it makes for itself is the shape of its own oversight. The governance board is the cross-functional executive body the methodology creates to run AI governance day to day, designed by the CEO at Level 1 and chartered here at Level 2. Keeping the two distinct in writing prevents a whole family of confusions later, and this series will always say which one it means.

The level begins by chartering the governance board. The structure the CEO chose becomes a standing cross-functional body with written decision rights, a meeting cadence, quorum, and the authority to grant exceptions. Every exception carries an owner and an expiry date. A small permanent team becomes the board’s operating arm and carries governance between meetings. Chartered decision rights are what convert governance from a meeting into a mechanism. The exception authority alone justifies the effort. Every real organization needs a way to say yes to something unusual without breaking the rules quietly, and an exception with an expiry date and an owner is governance working, not failing.

The board’s first product is risk classification, and everything keys off it. The board adopts written criteria that sort every AI system, present and future, into tiers of consequence. The criteria weigh impact on people, reversibility, data sensitivity, regulatory class, and how much the system acts on its own. Calibrated against the organization’s real inventory, the tiers become the load-bearing frame of the whole program. The criteria are written as criteria rather than case-by-case rulings, which lets them classify systems that do not exist yet. That includes the agents arriving now, whose autonomy is itself a classification dimension. The working test is usability. An intake analyst should be able to classify a proposed system in minutes, without the framework’s author in the room.

Two frameworks then make the tiers operable. Named owners attach to every tier, with response times in hours and days, so accountability belongs to people rather than committees. A permission table binds each tier to how much autonomy a system may have, with every combination decided in advance as permitted, conditional with a named approver, or forbidden. The table embodies a design choice worth making explicit. Below the highest tiers, the workable pattern is escalation. AI acts within boundaries, and humans handle the exceptions. A reviewer asked to approve every output will, through no fault of their own, end up approving without reviewing. Good governance protects its reviewers from that position rather than pretending diligence will overcome arithmetic.

Risk tier  ↓  /  Autonomy  →Advise onlyAct with approvalAct with oversightAct within bounds
Low✓ permitted✓ permitted✓ permitted✓ permitted
Moderate✓ permitted✓ permitted✓ permittednamed approver
High✓ permitted✓ permittednamed approver× forbidden
Critical✓ permittednamed approver× forbidden× forbidden
Risk tier down the side and autonomy across the top, with every combination settled in advance as permitted, conditional on a named approver, or forbidden.Figure 2.2 · Level 2 Permission Matrix · Illustrative pattern. Every client’s table is calibrated to its own risk appetite, written at Level 1. · Plaster Group’s AI Governance Methodology · © 2026 Plaster Group

One policy carries it all to the board of directors. The Level 1 and Level 2 decisions fold into a single AI policy, deliberately thin, and the board of directors formally ratifies it. This is the document the organization answers for, readable by a regulator, a customer, or a donor. It also opens two doors on purpose. Anyone inside the organization gets a protected way to raise a concern, and the people its systems affect get a named way to report a problem from outside. A policy the board has actually voted on carries a legitimacy no departmental memo can, and that legitimacy is what makes rules followed rather than bypassed.

The Rules Reach the People Already Using AI, and They Arrive as an Invitation

Alongside whatever has been formally rolled out, nearly every organization also carries shadow AI. These are tools employees adopted on their own, without sanction. The tools help, and asking felt slower than doing. IT leaders will recognize this as shadow IT’s newest generation, larger, faster growing, and touching real data from day one. It deserves a careful response. The people involved are usually among the organization’s most motivated adopters, doing their jobs better with the best tools they could find.

The methodology’s position is channel, never ban. It opens with an amnesty the governance board formally stands behind. Whatever happened before today carries no consequence. Every boundary is paired with a sanctioned alternative that genuinely substitutes, live before any restriction lands. The few hard limits on data are stated in plain language and drawn only where the data truly demands them. Shadow use itself is treated as evidence rather than violation. What people adopted on their own is the most honest map of real demand the organization will ever get, and the program routes it into its priorities. The rules are explained by role, in each audience’s own language. Employees follow rules they understand far better than rules they merely received. This is where the decentralized track from our first article is governed. Nobody’s work gets redesigned. The track receives clear boundaries, better sanctioned tools, and legitimacy for the personal solutions people build within them.

Working registers make the rest operable. Counsel signs a register of which laws apply to which systems and in which role, maintained as rows rather than essays. Compliance, in practice, is mostly careful bookkeeping done consistently. An impact assessment step asks, before any system is built or bought, whom it could affect and how badly. Routine cases take about thirty minutes, so the asking is built in rather than hoped for. A reasoned control list records which safeguards the organization runs and why, and later becomes the backbone of any certification effort. The stakeholders at this level are deliberately senior. Level 2 is where the organization decides its rules. Every level after applies and enforces them.

Level 3: Governance Where the Work Is Designed

AI is entering the organization along the two paths this series began with, and Level 3 is where they part ways. The decentralized wave has already met its governance at Level 2 through clear boundaries, sanctioned alternatives, and rules explained by role. Nobody is redesigning that work, so it largely does not appear in this level. Level 3 exists for the transformational track, the workflow redesign work. It carries the rules to the most economical place governance will ever operate, the design table. A concern caught while a workflow is still on the whiteboard costs a conversation. Caught at deployment, it costs a rebuild. Caught in production, it costs an incident. Nothing in that arithmetic is a criticism of any team. It is simply where the leverage lives, and the methodology puts its weight there deliberately.

Design-time governance at the whiteboard, shown on an example switcher journey. Four workflow steps, each carrying a risk tier, an autonomy setting and an oversight rule: spot the switcher, standard tier, acts, ten percent sampled. Compose the offer, elevated tier, acts, quotes audited. Verify identity and credit, high tier, advises only and executed by a human, every approval reviewed. Port and activate, elevated tier, acts, monitored live. The four steps feed a Classification Register marked confirmed buildable, which is what Level 4 enforces. Two notes: workflows under redesign have governance drawn in at the whiteboard, and AI point solutions that are bought rather than built have no workflow to redesign, so the tool is risk-classified at intake and then follows the same rules as everything else.
Four workflow steps on the whiteboard, each carrying a risk tier, an autonomy setting and an oversight rule, feeding one classification register that IT confirms buildable.Figure 2.3 · Design-Time Governance at the Whiteboard · Plaster Group’s AI Governance Methodology · © 2026 Plaster Group

The people who own the work make the calls. Domain owners, the executives whose departments the workflows belong to, classify every AI-enabled step as their teams design. They apply the Level 2 frameworks as a constraint that shapes the design rather than a review that rejects it. Their designers are taught the governance vocabulary first, before the design work begins, so classification becomes something designers do naturally. Reviews happen inside the design checkpoints that already exist rather than in a new bureaucracy. Governance that lives inside the templates teams already use gets applied. Governance that arrives as a separate form becomes a separate thing to skip, and the methodology is built with that human reality in mind.

Oversight is specified in names and numbers. For every step, the design states who reviews, how much, with what authority, and where issues escalate. “A human will check it” is never enough. That is no slight against the human. Unspecified oversight quietly becomes no oversight under real workloads. Each specification therefore carries an honest workload check, signed by the domain owner. Review rates are multiplied by real volumes and confirmed sustainable by the person whose team will do the reviewing. For systems that are high-risk under European law, this doubles as the statutory floor. Oversight must be assigned to people with the competence, training, and authority to actually exercise it.6

The design reviews the organization already runs are where the discipline is confirmed. Each existing quality checkpoint adds three governance questions. Are the classifications present and plausible? Are the oversight specifications real? Do workflows that cross department boundaries carry agreed terms on both sides of the line? No new gate is added to anyone’s calendar. The point of reviewing at all is the integrity of what comes next. The register that closes this level is only as trustworthy as the designs that feed it, and a register everyone can trust is what lets the enforcement layer build with confidence instead of double-checking upstream work.

Every step declares the data it runs on. While the design is still soft, each AI-enabled step records the source systems its data comes from, the quality that data must meet for its tier, how an output can be traced back to what went into it, and where its own outputs land. Where a step’s data will train or tune a model, those rules are written down too. All of it answers one question every organization eventually faces about an AI output. What went in, and where did it come from? Answered at design time, that question takes minutes. Reconstructed after an incident, it takes an investigation.

The level closes with a contract. Every classified step, with its tier, its autonomy, its oversight, and its data requirements, is delivered to the CIO’s organization as one register, and the CIO’s team confirms in writing that it can be built. There are two signatures on purpose. The business attests the content is true. IT attests it is buildable. Neither can honestly give the other’s attestation. That written confirmation turns a handoff into a contract, and it is the moment the deciding half completes its work. The business has decided. Now IT can enforce.

What the Deciding Half Buys You

Notice what Levels 1 through 3 did not require. No new technology, no reorganization, and no pause in the work already underway. They required decisions, made once, at the right altitude, by people with the standing to make them, then carried in writing to the place where work is designed. Organizations that do this discover something that sounds paradoxical until you have lived it. Governance speeds them up. Approvals move faster where criteria exist. Design teams move faster where boundaries are known. Leadership moves faster where exceptions are a process rather than a crisis, and where nobody is relitigating a decision that was made properly the first time.

What remains is the half that runs at machine speed. In the third and final article of this series, we walk the enforcement layer, where every rule made here becomes a protection that works automatically across the entire AI estate. We also walk the annual loop that keeps the whole arrangement honest year after year, and we show the on-ramp for the situation most readers are actually in. Governance can be built mid-flight, with AI already deployed, honestly and without a restart.

This series addresses “what” to do, not “how” to do it. If you are a business executive and would like help thinking through the “how,” please feel comfortable reaching out.

Sources

  1. 1.NIST AI Risk Management Framework, GOVERN 2.3 (executive leadership takes responsibility for AI risk decisions), with the generative-AI companion profile NIST-AI-600-1. https://www.nist.gov/itl/ai-risk-management-framework
  2. 2.COSO, “Enterprise Risk Management: Integrating with Strategy and Performance” (2017) and “Risk Appetite: Critical to Success” (2020). Management develops risk appetite; the board reviews and concurs. https://www.coso.org/guidance-erm
  3. 3.Deloitte Global Boardroom Program, “Governance of AI: A Critical Imperative for Today’s Boards,” 2nd edition (2025). Roughly a third of boards report AI is not yet on the agenda. https://www.deloitte.com/global/en/issues/trust/progress-on-ai-in-the-boardroom-but-room-to-accelerate.html
  4. 4.McKinsey, “The State of AI: How Organizations Are Rewiring to Capture Value,” March 2025. CEO-level oversight of AI governance among the elements most strongly correlated with bottom-line impact. https://www.mckinsey.com/capabilities/quantumblack/our-insights/the-state-of-ai-how-organizations-are-rewiring-to-capture-value
  5. 5.ISO/IEC 42001:2023, the international standard for AI management systems, Clause 5 (top-management leadership and commitment). https://www.iso.org/standard/81230.html
  6. 6.EU AI Act (Regulation (EU) 2024/1689), Article 26(2). Deployers assign human oversight to people with the necessary competence, training, and authority. https://eur-lex.europa.eu/eli/reg/2024/1689/oj

Frequently Asked Questions

How do you classify AI systems by risk to decide how much governance each one needs?

Through written risk-classification criteria, which the governance board adopts as its first product and which everything else keys off. The criteria weigh impact on people, reversibility, data sensitivity, regulatory class, and how much the system acts on its own, so a meeting notes assistant and a system that influences who receives aid are never governed the same way. They are written as criteria rather than case-by-case rulings, which lets them classify systems that do not exist yet, including agents whose autonomy is itself a classification dimension. The working test is usability. An intake analyst should be able to classify a proposed system in minutes.

Can the CEO delegate the decision about how AI governance is structured?

No. Only the CEO decides the shape of the cross-functional governance board, its chair, its seats, and where its small permanent support team will live, because every seat at that table is carved from some executive's territory. The research gives the decision unusual weight. McKinsey finds CEO-level oversight of AI governance among the elements most strongly correlated with bottom-line impact from AI, and ISO/IEC 42001 makes top-management ownership a requirement rather than a suggestion. Keep the two bodies distinct: the CEO designs the governance board, while the board of directors affirms the risk appetite and ratifies the policy.

How should we handle shadow AI, the tools employees adopted without approval?

Channel it, never ban it. The methodology opens with an amnesty the governance board formally stands behind, so whatever happened before today carries no consequence. Every boundary is paired with a sanctioned alternative that genuinely substitutes, live before any restriction lands, and the few hard limits on data are stated in plain language and drawn only where the data truly demands them. Shadow use is treated as evidence rather than violation, because what people adopted on their own is the most honest map of real demand the organization will ever get. The people involved are usually its most motivated adopters.

What does an AI permission table decide?

A permission table binds each risk tier to how much autonomy a system may have, with every combination settled in advance as permitted, conditional with a named approver, or forbidden. Settling it ahead of time is what stops the rules being renegotiated case by case. The table also embodies a design choice worth making explicit. Below the highest tiers the workable pattern is escalation, where AI acts within boundaries and humans handle the exceptions. A reviewer asked to approve every output will, through no fault of their own, end up approving without reviewing, and good governance protects reviewers from that position.

Shawn Plaster, Founder & CEO of Plaster Group

About the author

Shawn Plaster

Founder & CEO, Plaster Group

Shawn is the author of Plaster Group's five-level AI Governance Methodology and its 3-article Insights series, and leads the firm's enterprise AI transformation work.

Previous: Article 1: Why Governing AI Well Matters Now · Next: Article 3: Where Rules Become Protection

© 2026 Plaster Group, LLC. All rights reserved. This article may not be reproduced, distributed, or transmitted in any form without prior written permission from Plaster Group. Brief excerpts may be quoted for review or commentary purposes with attribution to the author and a link to the original article.

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