A policy is not oversight
An AI policy sets direction. It does not prove anyone is checking that the direction is being followed. Boards routinely accept the existence of a policy, a framework, or a certification as evidence that oversight is happening, when none of those things describe what is reviewed, by whom, or how often.
- The organisations that get caught out are rarely the ones with no AI policy. They are the ones whose policy was never tested against a real incident
- "We have a governance framework" and "a named person reviews this system's output every week" are different claims. Only the second is oversight
- A board that cannot name its three largest AI risks has not been shown a risk register. It has been shown a summary
- NACD's 2026 governance research found the share of boards assigning AI to a named committee, rather than leaving it as a standing full-board topic, has roughly quadrupled year over year. A committee with a charter is a different structure from a shared agenda item, and it changes who is accountable when something goes wrong
- Oversight built for conventional AI tools does not automatically transfer to agentic systems that act autonomously across multiple steps. NACD has flagged this as a distinct governance question in its own right
- Treat any unchecked item in Sections 1 or 3 as the priority. Ownership and human oversight are the load-bearing sections
- Ask for evidence, not descriptions, when reviewing management's next AI update
- Re-run this checklist after any AI incident, near-miss, or major vendor change, not just once a year




