The question is not whether AI is being used.
The real question is: Is it governed?
If you work in federal digital services, this is where things get serious. AI without governance is risk. AI with governance becomes capability.
And yes, that difference matters.
Why AI Governance Is Not Optional
Government does not get to experiment the way startups do.
Federal agencies operate inside:
- Public accountability
- Section 508 accessibility requirements
- Records retention laws
- Privacy mandates
- Oversight and audit structures
- FOIA exposure
- Continuous ATO processes
AI does not get a hall pass.
The guidance from Digital.gov on digital governance makes something very clear: governance is about decision rights, roles, standards, and accountability. It is not just policy documents sitting on a shelf.
AI must fit inside that structure.
Not around it.
Not ahead of it.
Inside it.
What Is AI Governance in a Federal Context?
AI governance is not a single memo.
It is a structured system that answers five questions:
- Who can use AI tools?
- For what types of work?
- With what data?
- Under what oversight?
- How is use documented and reviewed?
If your agency cannot answer those clearly, you do not have governance. You have experimentation.
And experimentation in public service has consequences.
Step 1: Define Acceptable AI Use
Start simple.
Create categories of AI use:
Low Risk
- Drafting internal content
- Summarizing non-sensitive documents
- Brainstorming ideas
- Plain language rewrites
Moderate Risk
- Public-facing content drafts
- FAQ generation
- Policy summaries
- Internal knowledge search
High Risk
- Case determinations
- Benefits eligibility decisions
- Regulatory interpretation
- Citizen data analysis
- Enforcement support
Most agencies should prohibit high-risk use cases until formal review processes exist.
This is not anti-AI.
It is pro-accountability.
Step 2: Establish Data Boundaries
Generative AI systems are probabilistic engines trained on large datasets. They are not inherently aware of federal privacy obligations.
Your policy must explicitly state:
- No PII into public AI tools
- No procurement-sensitive data
- No classified or CUI data
- No unpublished policy drafts unless within an approved environment
If this feels strict, good.
Public trust is fragile.
As outlined in Digital.gov’s guidance on trust, transparency and clarity are foundational to maintaining credibility in digital services.
You cannot build trust if you leak data through convenience.
Step 3: Require Human Oversight
AI-generated content must never be published without human review.
Period.
Every AI governance policy should include:
- Named accountable reviewers
- Mandatory fact-checking
- Accessibility validation
- Records retention tagging
- Clear authorship responsibility
AI assists.
Humans remain responsible.
If no one owns the output, the system will eventually fail.
Step 4: Build an AI Oversight Structure
Governance is not a one-time decision. It is an operating model.
Agencies should establish:
- An AI review committee
- A security representative
- A privacy officer
- An accessibility lead
- A records management liaison
AI decisions should flow through existing governance bodies where possible. Do not build a shadow governance layer.
Fold AI into your current digital governance structure.
That keeps it sustainable.
Step 5: Create Documentation & Audit Trails
If you cannot explain how AI was used, you are exposed.
Your policy should require:
- Logging AI use cases
- Maintaining decision documentation
- Tracking tool vendors and versions
- Retaining AI-assisted outputs under normal records policy
FOIA does not disappear because a machine helped write the document.
AI does not remove transparency requirements.
It increases them.
Step 6: Pilot With Guardrails
Start with contained pilots.
Good federal AI pilot examples include:
- Content summarization for internal policy libraries
- Plain language rewrites for public guidance
- Content audits of large website inventories
- Metadata tagging support
Avoid starting with citizen-facing decision systems.
Build governance muscle before scaling risk.
Common Mistakes Agencies Make
You would be surprised how often this goes wrong.
- Allowing AI before writing policy
- Blocking AI entirely and driving it underground
- Focusing only on cybersecurity and ignoring accessibility
- Ignoring records retention
- Failing to train staff on responsible use
AI governance fails when it is reactive instead of intentional.
AI Governance Is About Trust
This is the part that matters most.
Government digital services operate on legitimacy.
When a citizen reads your website, they assume:
- It is accurate
- It is accessible
- It is compliant
- It is accountable
If AI undermines any of those, trust erodes.
If governance reinforces them, trust strengthens.
The real risk is not AI itself.
The real risk is unmanaged AI.
A Practical Starting Checklist
If you are building your first AI safe-use policy, start here:
- Define approved and prohibited use cases
- Set strict data boundaries
- Require human review of all outputs
- Establish oversight roles
- Log AI usage and decisions
- Pilot in low-risk domains
- Train staff on responsible AI use
That is not flashy.
But it is operational.
And in federal environments, operational wins.
Final Thought
AI will continue to evolve. Models will improve. Tools will multiply.
Governance is what keeps agencies steady.
Innovation inside governance builds capability.
Innovation outside governance builds headlines.
Choose carefully.