How to Define Approval Authority for AI Work

Inventory governed decisions

List decisions such as approving a use case, authorizing data access, accepting residual risk, releasing an external output, granting an exception, changing a model, enabling an integration, or resuming after an incident. For each, record scope, consequence, required evidence, authority, delegate, expiry, and escalation.

NIST’s AI RMF Core states that leadership takes responsibility for AI risk decisions and that roles and responsibilities for human-AI configurations should be defined (AI RMF Core). NIST’s security RMF authorize step describes a senior official deciding whether security and privacy risk is acceptable based on an authorization package (Authorize step). Applicability must be tailored; this is not legal advice.

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Build an authority matrix

Use rows for decisions and columns for prepares, advises, verifies, recommends, approves, executes, monitors, and is informed. Name roles and limits rather than individuals where possible, then maintain current assignments. Add value, data, geography, duration, and risk thresholds.

Avoid assigning the same person incompatible duties without an explicit exception. A model owner can provide evidence without being the only approver of its own high-consequence use.

Worked authority record

Consider a synthetic customer-document assistant. A product owner proposes enabling a new connector. Security tests access scope, privacy reviews data handling, legal advises on contract terms, and the business owner approves the use case within a defined public-data boundary. Executive approval is required for confidential data.

An urgent request attempts to use the connector with confidential notes. The business owner cannot expand the boundary alone. The authority record routes the decision to the designated executive with the evidence package and an expiry for any temporary condition.

The weak workflow shows a green “approved” badge without object, scope, approver, evidence, or date. The repaired record binds approval to the use-case version, data class, connector configuration, and conditions.

Manage delegation and change

Delegation should name the exact decisions, duration, and constraints. Revoke it after role changes or expiry. Material edits to the approved object should invalidate approval and trigger the appropriate route. Emergency authority needs a narrow scope, logging, notification, and after-action review.

Test that system permissions match the authority matrix. Governance paperwork and technical enforcement can diverge.

Create an approval evidence packet

The packet should contain the decision request, current object version, relevant risk and control evidence, unresolved issues, recommendation, decision, conditions, approver identity, timestamp, expiry, and next review. Use stable identifiers and bind the approval to the object hash or version where feasible.

When an approver rejects or conditions a request, preserve the rationale and required next evidence. Do not convert “approved if connector scope is reduced” into a general approval. Downstream systems should check the current conditions at action time. Periodic review should confirm that the named authority still holds the role and that delegated permissions have not outlived their purpose.

Authority verification checklist

The output is an authority and evidence map. It does not establish compliance or continuous control effectiveness by itself.

Test the map with a changed object, absent approver, expired delegation, and conflicting specialist advice. Record whether the workflow stops, escalates, or requests fresh evidence exactly as the authority design specifies.

• Every governed decision has a defined object and consequence.
• Evidence requirements and thresholds are visible.
• Analysis, advice, approval, execution, and oversight are distinct.
• Delegation and emergency authority are scoped and expire.
• Approval binds to the current version and conditions.
• System permissions and workflow routes are tested against the matrix.
• Qualified review addresses legal, regulatory, and contractual requirements.