The sixteen themes of the AAIF governance working group, read against binding law

About this documentUpdated 2026-09-21ShowHide

Sean McDermott, Co-Founder and CEO, UnGovr

Written by Sean McDermott (with AI assistance) using the LexLint law library, which supplied every legal instrument, status and date on these pages.

Every law named here links to its summary page on lexlint.org, translated to English (if needed) and restructured to a standard format for human and code use. Every case links to the court's or the regulator's own record where one could be reached.

© 2026 UnGovr, publishing as LexLint. The text and the figures are licensed under Creative Commons Attribution-ShareAlike 4.0: share and adapt them, including commercially, with credit to LexLint (UnGovr) and under the same licence. Please contact LexLint at hello@ungovr.org to discuss other terms. Logos and wordmarks belong to their owners.

Corpus figures as of 2026-09-21.

Legal information, not legal advice. This document describes the law as written and dated; it does not apply it to any system. The notice at the foot says what that means.

The Agentic AI Foundation's Governance, Risk and Regulatory Alignment working group extracts requirements from frameworks under sixteen themes. This page reads the same themes against the LexLint software-law corpus: how each of the corpus's twenty obligation classes maps onto them, what the distribution says about where statutes speak and where they do not, and which handbook documents carry the material behind each theme and each of the group's three deliverables.

1What this is

Agentic AI Foundation

The Agentic AI Foundation (AAIF), a Linux Foundation foundation, runs a Governance, Risk and Regulatory Alignment working group whose charter sets three deliverables: a landscape of agentic-AI policy frameworks, a gap analysis, and distilled recommendations. Its monthly reports record the method it chose: about a dozen common themes, and extraction prompts to map frameworks, standards and legislation onto them consistently. In August 2026 the group circulated a workbook to its members with sixteen such themes, each with an extraction prompt to be run against one framework document at a time, and a reference guide of thirty frameworks to run them against. The workbook is not public; the themes are summarised here in the group's own words.

The prompts share one contract: classify every provision by type, decompose compound statements into atomic requirements, keep the exact modal language, and record for each requirement an identifier, the text, the type, the obligation strength, the applicable entity, the source clause and a confidence. Two of the prompts' rules matter most: do not infer applicability beyond what the source states, and say "legal interpretation required" where legal analysis is needed.

The working group's sixteen themes Sixteen labelled cells, one per theme, each with its identifier and icon. Governance & Accountability: Ownership; approvals; RACI; risk acceptance; governance bodies; accountability structures. Use-case Classification & Risk Tiering: Allowed/prohibited uses; risk tiers; tiered controls; autonomy levels; classification criteria; re-classification triggers. Architecture: Reference patterns; trust boundaries; control placement; multi-agent topology; isolation; separation of concerns. Agent Identity & Delegation: AuthN/Z model; acting-on-behalf-of; agent registry; credential lifecycle; delegation scope; non-repudiation. Guardrails & Policy Constraints: Business rules; policy-as-code; content filters; hard stops; behavioral boundaries; policy enforcement points; constraint override. Data Protection & Privacy: Personal data; data minimization; retention; residency; consent; cross-border transfer; special category data; privacy-by-design. Security & Access Controls: Least privilege; secrets management; network segmentation; tool permissions; authentication; vulnerability management; capability confinement. Model/Agent Risk Management: Validation; robustness; drift monitoring; change control; benchmarking; bias/fairness; decommissioning; version control. Human Oversight: Human in or on the loop; escalation paths; human waterfall; override/kill switch; mandatory approval; supervision frequency; automated oversight. Action Management: Pre-execution checks; dual control; reversibility tiers; undo infrastructure; action scope limits; side-effect disclosure. Monitoring & Logging: Audit trails; prompt/tool logs; decision logs; log retention; log integrity; tamper-evidence; real-time alerting. Testing & Red Teaming: Prompt injection; tool abuse; autonomy failures; adversarial testing; pre-deployment testing; test coverage; remediation. Third-Party & Supply Chain: Vendor due diligence; model provenance; tool vetting; AI bill of materials; service levels; supply chain risk; third-party incident notification. Incident Response: Detection; containment; incident classification; regulatory notification; root cause analysis; recovery; post-incident review. Transparency & User Disclosure: AI disclosure; user notices; explanations; user expectations; consent; labeling; deception prohibition; capability limits. Recordkeeping & Auditability: Retention schedules; reproducibility; audit readiness; record integrity; regulatory reporting; archival; destruction. T01 Governance & Accountability T02 Use-case Classification & Risk Tiering T03 Architecture T04 Agent Identity & Delegation T05 Guardrails & Policy Constraints T06 Data Protection & Privacy T07 Security & Access Controls T08 Model/Agent Risk Management T09 Human Oversight T10 Action Management T11 Monitoring & Logging T12 Testing & Red Teaming T13 Third-Party & Supply Chain T14 Incident Response T15 Transparency & User Disclosure T16 Recordkeeping & Auditability
Figure 1. The sixteen themes, each with the icon this page uses for it.

This page reads the same sixteen themes against a different source. Instead of thirty frameworks, the input is binding law by jurisdiction: the 6,825 requirement lines the LexLint software-law corpus carries for every AI, privacy, scraping and cybersecurity instrument it holds, each one already atomic, already tied to a citation, and already dated. The corpus has an axis of its own for those lines, twenty obligation classes recorded on each instrument by the research, and the requirement register in the handbook is keyed on it. The bridge between the two is a rule: a line joins a theme when its instrument's class is one the theme's prompt is about, or when the line's own wording matches the theme's key concepts. Section 2 prints that bridge in both directions, section 3 says what the result shows, and sections 4 and 5 say where in the handbook the material behind each theme and each deliverable sits. The sixteen themes, one by one holds each theme's counts and a sample of its lines.

2The crosswalk

One row per obligation class, largest first. The third column names the theme the class feeds outright, where a theme's prompt is about that class; the last column names the other themes that admitted at least a quarter of the class's lines by wording, which is where the overlap between the themes shows. Since the theme rules are generous, a line sits in 70% of cases in two or more themes, and a theme's count is an upper bound on what a careful reader would keep. 510 lines fall under no theme at all; they are in the handbook's register and its file, and absent from the theme file.

Obligation classLinesFeeds outrightAlso reached by wording
Secure the system and the data in it 1,693 T07 Security & Access Controls T16 79% · T06 48% · T15 47% · T13 27%
Govern the system: policies, roles, assessments 1,530 T16 Recordkeeping & Auditability T07 57% · T06 50% · T15 41% · T13 27%
Disclose the use of AI 1,104 T15 Transparency & User Disclosure T06 76% · T07 51% · T16 40%
Get consent first 1,091 T06 Data Protection & Privacy T07 63% · T16 58% · T15 46% · T13 33% · T02 31% · T08 28%
Report to a regulator 1,046 T16 Recordkeeping & Auditability T14 44% · T07 44% · T15 34% · T06 26%
Do not get in without authorisation 712 T07 Security & Access Controls T06 54% · T15 50%
Do not do the named thing 705 T02 Use-case Classification & Risk Tiering T06 56% · T15 31%
Honour the person's rights over their data 623 T06 Data Protection & Privacy T15 94% · T07 50%
Keep records for a set time 499 T16 Recordkeeping & Auditability T06 90% · T07 88% · T15 55% · T13 46% · T08 34%
Hold a licence or registration 367 T13 Third-Party & Supply Chain T07 73% · T06 72% · T16 71% · T15 36% · T08 28%
Limits on biometric use 310 T06 Data Protection & Privacy T02 68% · T15 25%
Tell somebody when there is a breach 300 T14 Incident Response T16 70% · T06 58% · T15 37%
Assess the impact on personal data first 290 T08 Model/Agent Risk Management T16 96% · T06 89% · T07 81% · T13 42% · T15 31%
Conditions on sending data abroad 283 T06 Data Protection & Privacy T07 47% · T13 36% · T15 33%
Label generated content 147 T15 Transparency & User Disclosure none above a quarter
Check the user's age 134 none: reached by wording alone T06 100% · T02 82%
Put the terms in the contract 56 T13 Third-Party & Supply Chain T06 100% · T07 89% · T16 82% · T15 38% · T08 34%
Respect text and data mining opt-outs 54 T13 Third-Party & Supply Chain T16 48%
Meet a design code 45 T06 Data Protection & Privacy T16 58% · T15 56% · T08 33% · T13 29%
Credit or licence the publisher's content 31 T13 Third-Party & Supply Chain T16 87% · T07 55%
No class recorded on the instrument 2,113 none: reached by wording alone T06 40% · T15 26%

The same bridge from the themes' side: for each theme, the classes its lines carry, largest first, and how many of its lines come from an instrument with no class recorded, which is the share of the theme that rests on wording alone.

ThemeLinesClasses its lines carryNo class
T01 Governance & Accountability 272 secure the system and the data in it 151 · govern the system: policies, roles, assessments 149 · get consent first 64 · disclose the use of AI 51 36
T02 Use-case Classification & Risk Tiering 924 do not do the named thing 705 · get consent first 333 · limits on biometric use 211 · govern the system: policies, roles, assessments 154 68
T03 Architecture 39 secure the system and the data in it 20 · get consent first 19 · govern the system: policies, roles, assessments 18 · assess the impact on personal data first 16 12
T04 Agent Identity & Delegation 231 disclose the use of AI 71 · secure the system and the data in it 65 · govern the system: policies, roles, assessments 62 · honour the person's rights over their data 47 54
T05 Guardrails & Policy Constraints 357 do not get in without authorisation 75 · disclose the use of AI 73 · do not do the named thing 72 · get consent first 70 67
T06 Data Protection & Privacy 3,290 get consent first 1,091 · disclose the use of AI 834 · secure the system and the data in it 818 · govern the system: policies, roles, assessments 771 835
T07 Security & Access Controls 2,811 secure the system and the data in it 1,693 · govern the system: policies, roles, assessments 868 · do not get in without authorisation 712 · get consent first 691 252
T08 Model/Agent Risk Management 583 govern the system: policies, roles, assessments 379 · secure the system and the data in it 350 · get consent first 303 · assess the impact on personal data first 290 72
T09 Human Oversight 150 govern the system: policies, roles, assessments 45 · disclose the use of AI 37 · honour the person's rights over their data 33 · report to a regulator 28 46
T10 Action Management 137 get consent first 37 · govern the system: policies, roles, assessments 33 · do not get in without authorisation 32 · secure the system and the data in it 31 37
T11 Monitoring & Logging 168 secure the system and the data in it 102 · govern the system: policies, roles, assessments 94 · get consent first 55 · keep records for a set time 42 23
T12 Testing & Red Teaming 20 secure the system and the data in it 10 · report to a regulator 8 · govern the system: policies, roles, assessments 6 · do not do the named thing 1 4
T13 Third-Party & Supply Chain 1,147 secure the system and the data in it 450 · govern the system: policies, roles, assessments 414 · hold a licence or registration 367 · get consent first 357 171
T14 Incident Response 1,000 report to a regulator 462 · secure the system and the data in it 378 · tell somebody when there is a breach 300 · govern the system: policies, roles, assessments 171 257
T15 Transparency & User Disclosure 2,708 disclose the use of AI 1,104 · secure the system and the data in it 792 · govern the system: policies, roles, assessments 621 · honour the person's rights over their data 588 548
T16 Recordkeeping & Auditability 2,693 govern the system: policies, roles, assessments 1,530 · secure the system and the data in it 1,332 · report to a regulator 1,046 · get consent first 637 179

3What the distribution says

Four themes carry most of the binding law: data protection and privacy (2,791 lines in force), security and access controls (2,524), transparency and USER disclosure (2,224) and recordkeeping and auditability (2,241). These are the themes where a statute, rather than a framework, is the source of the requirement, and they are where a gap analysis against binding law will find the most to measure.

Three themes are thin, and the thinness is the finding. Architecture has 39 lines, testing and red teaming 20, monitoring and logging 168. Binding law rarely tells an OPERATOR how to structure a system, how to test it, or what to log in what format; it tells the OPERATOR what outcome to secure and what record to be able to produce. Those three themes are framework territory, and the frameworks in the group's reference guide are the right source for them. What a statute adds is the outcome the framework control has to serve, which is why the recordkeeping theme is large while the logging theme is small.

Use-case classification and risk tiering (924 lines) is dominated by prohibitions: the law's way of tiering is to name what may not be done at all. Human oversight (150) and action management (137) are small but spread across many jurisdictions (98 and 91 respectively), which is the pattern of a duty that arrives through privacy law's automated-decision rules rather than through an AI statute. Incident response (1,000) is almost entirely breach notification, the oldest and most uniform family in the LexLint software-law corpus.

The themes and the classes are not two names for one thing. A theme is a family of controls an organisation might adopt; a class is a family of duties a statute imposes. Where the two coincide, as with breach notification and incident response, the crosswalk is one row. Where they do not, as with architecture, the theme has almost no law under it and the class has no theme that is about it, and each side of the table says so in its own terms.

4Where the handbook reads each theme

The handbook at lexlint.org/agents is written for people building and running agents and is organised by their questions, not by the themes. This table says, for each theme, which of its documents carry the material a reader mapping that theme would want, and why. Each entry is the document's number in the handbook and its short name.

ThemeRead in the handbook
T01 Governance & Accountability 1, The 6 parties: who holds a duty, by role, along the chain from maker to user.
4, The requirement register: the governance class: policies, roles and assessments.
T02 Use-case Classification & Risk Tiering 3, Global AI law: the tiering thread: a prohibited top, a high-risk class, a lighter rest.
4, The requirement register: the prohibition class, which is how statutes tier.
T03 Architecture 6, What you must constrain: the layers a duty lands on; statutes name outcomes, not structure.
T04 Agent Identity & Delegation 1, The 6 parties: who acts for whom, and which party a duty follows.
2, Where the parties are: which party's position sets the law that applies.
T05 Guardrails & Policy Constraints 6, What you must constrain: what an operator constrains at run time, and which law sets each limit.
T06 Data Protection & Privacy 4, The requirement register: consent, data-subject rights, transfer, biometric and design-code classes.
3, Global AI law: the older privacy law that already binds an agent.
T07 Security & Access Controls 4, The requirement register: the security and access-restriction classes.
6, What you must constrain: the control layers, with security duties per layer.
T08 Model/Agent Risk Management 4, The requirement register: the impact-assessment class.
3, Global AI law: conformity and risk assessment across the AI laws.
T09 Human Oversight 3, Global AI law: the oversight thread: a person able to intervene.
6, What you must constrain: override and approval as runtime controls.
T10 Action Management 6, What you must constrain: pre-execution checks, scope limits and reversibility.
9, Legal constraints at the gateway: loading legal constraints into the gateway an agent runs through.
T11 Monitoring & Logging 7, What you must be able to show: what the record has to hold; statutes ask for the record, not the log format.
8, Jurisdiction in logs: the field a record keeps getting wrong.
T12 Testing & Red Teaming 6, What you must constrain: pre-deployment testing where a statute names it; most do not.
T13 Third-Party & Supply Chain 10, Open source and legal exposure: what a project owes the people who run its code.
4, The requirement register: the licensing, text-and-data-mining, attribution and contract-terms classes.
T14 Incident Response 11, Incident reporting clocks: every reporting clock an incident starts, by family and rung.
12, Incident command: which of those clocks one incident starts, and in what order.
T15 Transparency & User Disclosure 3, Global AI law: the tell and mark threads: disclosure at the interaction, marking the output.
4, The requirement register: the disclosure and content-labelling classes.
T16 Recordkeeping & Auditability 7, What you must be able to show: the record an operator must be able to produce, and for how long.
13, The public record: who can read that record afterwards when a public body holds it.

5The three deliverables, and what is published against each

The charter names three deliverables. For each, the handbook documents that bear on it, with the reason each is named.

A landscape of agentic-AI policy frameworks

What exists, and where the frameworks agree and disagree across jurisdictions.

A gap analysis

Where the regulatory environment has gaps, measured against a baseline.

Distilled recommendations

Risk classification, organisational governance of deployed agents, and agent bills of materials.

6The files

Three files are cut from the same lines on the date in this page's byline, and all three will be regenerated when the corpus moves.

  • theme-crosswalk.csv: the two tables in section 2 as one file, a row per obligation class with its counts, the theme it feeds outright, and how many of its lines each of the sixteen themes admits, with a last row for the lines whose instrument records no class.
  • theme-register.csv: every requirement line that falls under at least one theme, one row per line, with the theme identifiers first and then the columns the prompts' contract asks for, plus the party, hook and tier columns the corpus adds. Its columns are described on the sixteen themes, one by one.
  • requirement-register.csv: the handbook's register, every line on the corpus's own axes with the obligation classes and no theme columns, described in the requirement register.

theme-crosswalk.csv is licensed separately from the text and figures around it, under Creative Commons Attribution-NonCommercial 4.0 rather than the ShareAlike terms in the byline: use it for noncommercial purposes with credit to LexLint (UnGovr), and contact LexLint at hello@ungovr.org to discuss commercial use. The other two files state their own terms where they are offered: theme-register.csv in section 3 of the sixteen themes, and requirement-register.csv in section 6 of the requirement register.

7What this page does not claim

It does not say that any line binds any particular organisation. That is the applicability question, and it is answered per deployment from the roles a system holds and where its parties are, which is what the first documents of the handbook are about. The theme assignment is a rule applied to text, reviewed in samples, not a finding made line by line, and the crosswalk is a description of where that rule put the lines, not a proposal that the themes or the classes be changed. Every entry, on these pages and in the files, links to the source the corpus researched it from, so that the rule can be checked against the law.