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Singapore Model AI Governance Framework · IMDA and PDPC guidance

Singapore Model AI Governance Framework implementation for AI decisions you can explain and defend.

Singapore's Model AI Governance Framework asks one thing of every organisation using AI: that its decisions are explainable, transparent and fair, and that its solutions put people first. Sterling's expert and experienced consultants turn it into owned governance and working controls with your teams, in 60+ countries. IMDA and PDPC publish it as voluntary guidance, and no certificate exists. We help our clients put it into practice and prove it.

  • Fixed scope, one proposal: consulting, Effivity software, Sterling Academy access and internal auditor training, as applicable to your standard, in one proposal
  • A team of expert and experienced AI governance consultants, advising on management systems across sectors and countries since 2003
  • The Sterling Promise: 100% on-time completion, 100% success, 8,100+ client engagements. Sterling works with you to put the framework in place; there is no certificate to issue

8,100+ client engagements in 60+ countries.

Why organisations choose Sterling
  • Allianz
  • Emirates Flight Catering
  • Etihad Rail
  • Haier
  • Whirlpool
  • Emerson
  • Olam
  • Piramal Pharma Solutions

What it is

What is the Singapore Model AI Governance Framework?

The Model AI Governance Framework is Singapore's guidance for private sector organisations on deploying artificial intelligence responsibly. It is published by the Infocomm Media Development Authority (IMDA) and the Personal Data Protection Commission (PDPC), and its authors describe it as living and voluntary. It turns ethical principles into practice: who is accountable for AI, how involved people stay in decisions, how data and models are managed and what customers are told.

Its owners describe it as agnostic to algorithm, technology, sector, scale and business model, so a bank, a retailer and a manufacturer can apply the same structure. Companion documents include the Implementation and Self-Assessment Guide for Organisations (ISAGO) and two volumes of a Compendium of Use Cases.

This page covers Singapore's framework family. For the US voluntary framework, see our NIST AI RMF page; for a certifiable AI management system, see ISO/IEC 42001.

Current edition. The first edition appeared on 23 January 2019 and the second edition, the current text, on 21 January 2020. Two further frameworks extend it: the Model AI Governance Framework for Generative AI, released by the AI Verify Foundation and IMDA on 30 May 2024, and the Model AI Governance Framework for Agentic AI, announced by IMDA on 22 January 2026. Being voluntary, it has no transition deadline.

Who it is for

Who should implement the Model AI Governance Framework?

Any organisation whose AI makes or supports decisions about customers, employees or the public, whether built in-house or inside a vendor's software. Four typical starting points:

  • Enterprise customers are asking how you govern AI. Security and vendor questionnaires now include sections on model oversight, training data and explainability.
  • A tender or partnership expects responsible AI practices. Bid teams need a policy, an owner and evidence of operating controls, not a statement of values written the night before submission.
  • Your AI uses personal data. PDPC administers the Personal Data Protection Act, and the same commission co-published this framework. A PDPA programme is a natural base for the framework.
  • Your group sets an AI policy and each entity must apply it. A regional headquarters in Singapore often needs one governance model that subsidiaries in other countries can follow and report against.

Requirements

What are the Model AI Governance Framework requirements?

Strictly, the framework sets expectations rather than mandatory requirements. It rests on two guiding principles and organises its practices into four areas; the Generative AI and Agentic AI frameworks add dimensions of their own. The list below follows the owners' titles; your programme adopts the parts that apply to the AI you use.

  • Guiding principle one: decisions made with AI should come from a process that is explainable, transparent and fair.
  • Guiding principle two: AI solutions should be human-centric.
  • Internal Governance Structures and Measures: clear roles, responsibilities and oversight for the AI an organisation deploys.
  • Determining the Level of Human Involvement in AI-augmented Decision-making: decide how far people stay involved in decisions that AI supports, in proportion to the risk.
  • Operations Management: manage data, models and their performance through development, deployment and review.
  • Stakeholder Interaction and Communication: tell customers and others how AI is used and give them a way to respond.
  • Generative AI framework, nine dimensions: Accountability; Data; Trusted Development and Deployment; Incident Reporting; Testing and Assurance; Security; Content Provenance; Safety and Alignment R&D; AI for Public Good.
  • Agentic AI framework, four dimensions: bound risks upfront, keep humans meaningfully accountable, apply technical controls across the agent lifecycle, and enable end-user responsibility.

What evidence shows the framework is working?

An inventory of AI systems with owners, a documented approach to deciding human involvement for each use case, records of data sourcing and model testing, monitoring results, incident logs, customer-facing explanations and a completed ISAGO self-assessment. Where testing is useful, AI Verify reports can sit alongside these records. We keep them in Effivity so a customer or board can see governance operating, not just described.

Implementation

How do you implement the Model AI Governance Framework?

There is no certification audit at the end, so the route is judged by whether governance actually shapes AI decisions. We take you through it in five steps, using the framework's own areas as the backbone.

  1. 01
    Inventory your AI and agree the scope.List the AI systems in use, including features inside purchased software, and decide which frameworks apply: the 2020 framework, the Generative AI framework, the Agentic AI framework or all three.
  2. 02
    Gap analysis against the four areas.Compare current governance, oversight, operations and communication with the framework, using ISAGO questions, and agree actions, owners and dates.
  3. 03
    Design governance and human oversight.Assign accountability, set a risk-based method for choosing the level of human involvement, and approve the AI policy.
  4. 04
    Put operational controls and communication in place.Data and model controls, testing (with AI Verify where it fits), monitoring, incident handling and plain-language disclosures for customers.
  5. 05
    Self-assess, report and keep it current.Complete the ISAGO self-assessment, report to management and review as models, vendors and IMDA guidance change.

Check the route before you sign. IMDA and PDPC do not certify organisations against this framework, so treat any offer of a "Model AI Governance Framework certificate" with caution. The AI Verify Foundation's AI Tester Accreditation Programme, which it expects to open in the third quarter of 2026, accredits firms that test AI systems; it does not certify the systems or the organisations. If you need a certificate, ISO/IEC 42001 is certified by an accredited certification body, and the accreditation can be verified directly.

Cost

How much does Model AI Governance Framework implementation cost?

Cost depends on how much AI you run and how consequential its decisions are, more than on headcount. Our proposal shows every component and one all-inclusive proposal.

Cost componentWhat affects it
Consulting and implementationThe number and risk of AI use cases, existing governance, and Design™ or Drive™ support
TestingWhether you run AI Verify testing yourselves or engage a testing provider, and how many systems are tested
Internal resourcesTime from data science, legal, risk and business owners
Software and learningIncluded in a Sterling engagement: Effivity for registers and records, and Sterling Academy access for your people, as confirmed in the proposal
Continued supportPeriodic reviews, new use cases and updates when IMDA extends the framework, under Sustain™

What moves the price

  • How many AI systems are in scope, and how many are generative or agentic
  • Whether decisions affect customers' money, health, jobs or access to services
  • Reliance on third-party models and vendors
  • Countries and entities that must follow the same model

What a Sterling proposal always shows

  • Scope, deliverables, assumptions and exclusions in writing
  • Any third-party testing costs shown separately
  • Effivity, training and Academy access itemised at no additional cost
  • A single all-inclusive proposal

Timeline

How long does Model AI Governance Framework implementation take?

Most programmes take around three to six months, as an estimate: long enough to inventory the AI, agree governance, embed controls and run at least one review cycle. The pace depends on how many systems are in scope, how quickly owners can be named and how much evidence already exists.

PhaseWhat determines the pace
Inventory and gap analysisHow visible AI use is across departments and vendors
Governance and oversight designManagement decisions on accountability and approval of the AI policy
Controls and testingTechnical changes, testing effort and vendor cooperation
Self-assessment and reviewControls running long enough to show results, then the ISAGO review and management reporting

If a customer questionnaire or tender has a date, tell us at the start; we will say what can be evidenced by then and what cannot.

Your engagement

What your Model AI Governance Framework engagement includes

Engagements follow Sterling OS™: Design™ (we guide, your team builds) or Drive™ (we manage the build), as alternatives; Sustain™ keeps governance current; Automate™ is Effivity. Sterling does not certify, attest or validate AI systems; we help you implement the framework and evidence it.

  • AI inventory, gap analysis and plan

    Each AI system owned, gaps found, actions dated.

  • Governance, policy and oversight model

    Accountability, AI policy and human-involvement method, built with leadership.

  • Effivity ISO & GRC software

    Registers, risks and records in Effivity, included with the engagement at no additional cost.

  • Training for everyone

    Internal auditor training, as applicable to your standard, and preferential Sterling Academy access, including complimentary awareness training for your people as part of the engagement.

  • Operational controls and disclosures

    Data and model controls, testing, incidents and customer explanations.

  • Self-assessment and review

    ISAGO self-assessment and management review, actions closed.

No certificate exists for the framework; your organisation remains accountable for its AI.

How Sterling implements ISO and GRC standards

Effivity · AI governance registers and records, included in every engagement

How Effivity helps you run the Model AI Governance Framework day to day.

Effivity is the ISO and GRC automation platform built by the Sterling group and used in 50+ countries. Your consultant sets up a workspace for the framework within the agreed scope: the AI inventory, risks, documents, training records, audits, incidents and management review in one place, so governance runs in daily work and a customer or board sees live evidence. Sterling consulting clients receive their Effivity subscription included with the engagement, at no additional cost.

Effivity: Context of the Organisation dashboard with issues, interested parties and scope
Effivity · Context of the Organisation dashboard
Internal governance

Roles, policy and AI inventory

Owners, approvals and the AI policy held with a register of every system in use.

Human involvement

Risk-based oversight decisions

Each use case assessed for harm, with its chosen oversight level and review date recorded.

Operations management

Data, models and monitoring

Data sourcing, testing results and performance reviews kept as records, with actions tracked.

Stakeholder interaction

Disclosures and feedback

Customer explanations under document control; queries and complaints logged and answered.

Incident reporting

AI incidents and corrective action

Incidents raised, investigated and closed with root cause and evidence.

Testing and assurance

Audits and test evidence

Internal review programmes, findings and attached test reports in one trail.

Accountability

Training and awareness

Training records for developers, owners and users, linked to Sterling Academy.

Across the system

Your own forms and workflows

Intake forms for new AI use cases and approval workflows, configured without code.

What this means when a customer asks

When a buyer's due-diligence team asks who approves new AI, how oversight is set and what happened after the last incident, each answer is a screen with dates, owners and evidence. Sustain™ runs in the same workspace, so the answers stay current.

In your engagement

  • Subscription included with the engagement, at no additional cost
  • Set up by your Sterling consultant within the agreed scope
  • Existing registers and records migrated
  • Admin and user training for your team
  • Modules for ISMS, privacy and QMS when you add other standards

Sterling Academy · AI governance e-learning

Train the people who build, procure and use AI.

Sterling Academy provides video e-learning with practice checkpoints, a final exam and a numbered Certificate of Completion for each learner, verifiable online. Sterling consulting clients receive preferential Sterling Academy course access and special pricing through their Sterling consultant, including complimentary awareness training for their people as part of the engagement.

  • Awareness for every employee who uses AI tools at work
  • Learning for AI owners, risk and compliance leads
  • Internal auditor training, as applicable to your standard, as part of the engagement
  • Progress reports by department for management review
  • New joiners trained as they arrive

Why Sterling

Why choose Sterling for Model AI Governance Framework consulting?

AI governance fails when it sits in a policy nobody reads. We connect it to the processes you already run for privacy, security and quality, so the framework becomes part of how AI is approved, monitored and explained.

Governance programmes in 60+ countries since 2003

One engagement team for your Singapore headquarters and the entities that follow its model, with offices in 21 countries.

All-inclusive proposal

Consulting, Effivity, training and Academy access in one proposal, with any third-party testing shown separately.

One system for AI, privacy and security

The framework linked to your PDPA, ISO/IEC 27001 or ISO/IEC 42001 work, so evidence is gathered once.

Expert and experienced consultants

Consultants who have built risk and management systems across sectors, and who design oversight your data scientists and business owners will actually use.

The Sterling Promise

What the Sterling Promise means for Model AI Governance Framework implementation

100%on-time completion · success · 8,100+ client engagements

We stay with you until the agreed Model AI Governance Framework implementation outcome is achieved, supporting design, implementation and the first self-assessment. Clear explanations, practical delivery, included software and employee learning leave you with lasting capability rather than a policy on a shelf.

The engagement identifies the framework, scope, outcome and responsibilities. Your organisation supplies accurate information and puts the agreed controls into use. No body certifies against this framework, and your organisation remains accountable for its AI. Our commitment concerns the agreed consulting support, not a promise of every future contract award or error-free AI.

FAQs

Model AI Governance Framework FAQs

Is the Singapore Model AI Governance Framework mandatory?

No. IMDA and PDPC describe the 2020 framework as voluntary and invite organisations to adapt it. Laws that apply to your AI, such as the PDPA when personal data is involved, still apply in full; we work alongside your legal advisers on those.

Can my company be certified to the Model AI Governance Framework?

No certification exists for it. You can evidence alignment through the ISAGO self-assessment and, where useful, AI Verify testing reports. If a customer insists on a certificate, ISO/IEC 42001 is the certifiable AI management system standard, and the two can be implemented together.

What is the difference between the Model AI Governance Framework and AI Verify?

The framework says what good AI governance looks like; AI Verify helps test whether a system behaves that way. IMDA calls AI Verify an AI governance testing framework and software toolkit, and it produces reports, and states that testing does not guarantee a system is free from risk or bias.

Does the framework cover generative AI and AI agents?

Yes, through two separate frameworks. The Generative AI framework of 30 May 2024 adds nine dimensions, from accountability to content provenance, and the Agentic AI framework of 22 January 2026 addresses limits on agents' powers, human checkpoints and lifecycle controls.

Can we align with NIST AI RMF and ISO/IEC 42001 at the same time?

Yes. The AI Verify Foundation states that AI Verify is aligned with the NIST AI RMF and ISO/IEC 42001, among other frameworks. We build one set of governance records and map it to each framework, so work done for one counts for the others.

Keep exploring

More on Singapore Model AI Governance Framework and related standards

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