Module D2 · Governing Data & AI · Executive Leaders Track · 2026
Module D2 · Half-day · Executive Leaders Track

Governing
Data
and AI

Chain of accountability, role of the Board, and executive obligations

Data and AI governance is no longer the exclusive domain of the CIO. EU AI Act, DORA, GDPR — these regulations engage executives personally. This module establishes the chain of accountability from the Board to the front line, and what the Executive Committee must review, approve, and reject.

Executive objectives
01Master the chain of accountability: Board · Executive Committee · Operations
02Identify what EU AI Act and DORA require at the executive level in 2026
03Position your organization across the 5 Data & AI maturity levels
04Know what the CDO / CAIO must report — and how frequently
Executive Committee CEO · Deputy CEO · Board Members CDO · CIO · DPO Recommended: D1 completed
Pejman Gohari · CDO · Chief AI Officer · ORBii
25 years in the field · DataLab SG · Data Factory Bpifrance · BPCE SI · DUNOD Author · IESEG Professor
academy.orbii.tech
ORBii.Academy · D2 · Governing Data & AI · Executive Leaders TrackConfidential · 202601
D2 · Governance · 02
Section 1

The chain of accountability — 3 levels, zero gray areas

Data & AI governance is not a technical topic — it is a matter of organizational accountability. Each level has a precise role. Breakdowns occur when these roles overlap or remain vacant.

1
Board of Directors · Strategic Oversight
The Board approves the company's Data & AI policy, validates major investments, ensures that AI risks are covered in the risk map, and receives an annual Data & AI maturity report. It does not manage — it oversees and sanctions the strategy.
Approve AI policy Validate major budgets AI risk mapping Annual maturity report
2
Executive Committee · Executive Steering
The Executive Committee approves priority use cases, validates high-risk AI deployments, arbitrates resources, tracks Data & AI KPIs, and ensures regulatory compliance. The CDO/CAIO reports directly to this level. This is where the Data & AI culture of the organization is decided.
Priority use case validation High-risk deployments Resource arbitration EU AI Act / DORA compliance
3
Operational Level · Execution and Control
The CDO, Data Engineering, MLOps, Compliance, and Business teams ensure implementation, data quality, production model oversight, and regulatory audits. This level executes and escalates alerts. It does not set the strategy — it implements it.
CDO · CIO · DPO Data Engineers · MLOps Compliance · Risk Business Product Owners
⚠️
The most common pitfall: The Executive Committee fully delegates AI governance to the CIO or CDO, without a reporting framework or validation of high-risk use cases. Result: AI projects deployed without executive approval, and liability that escalates to the executive in case of incident. Technical delegation ≠ delegation of accountability.
ORBii.Academy · D2 · Governing Data & AI · Executive Leaders TrackConfidential · 202602
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