What your instrument says
A charity board answers to charity law and, voluntarily, to the governance code most boards in the sector use as a reference point. An academy trust board answers to charity law and company law at once, and to the Department for Education’s handbook for academy trusts. None of those names AI.
What they all do say, in one form or another, is that trustees must exercise reasonable care and skill and must be able to show that decisions were taken properly. That is the obligation AI reaches, and it reaches it through the executive team rather than through the board.
What it does not answer
Whether the staff using these systems can tell when one is wrong. In a school that question has a sharper edge than in most organisations, because the output lands on a child: a predicted grade, a safeguarding flag, a piece of feedback, a letter to a parent.
And whether the capability the trust is quietly losing was the capability it existed to build. A charity that automates the part of its work where judgement was the service has changed what it is, whether or not anyone decided to.
What you can establish before your next meeting
Where these systems now touch a decision about a person: a pupil, a beneficiary, a grant, a case. Who is named as the human check on each. What staff have been told they may and may not do, and whether anyone has checked that the policy survives contact with a busy term.
One question is worth more than the rest of the agenda item: has anyone here overridden one of these systems, and what happened? If nobody has, the board does not yet know whether its oversight works.
Where this is the wrong call
I do not write AI risk registers, map controls against the EU AI Act, run conformity assessments, build governance frameworks or draft committee papers. Firms that do that work properly exist and several of them are very good. This is the question those exercises leave open: whether the people named in your framework could actually detect a wrong answer, whether anyone has ever overridden a system, and what the organisation could still do if it stopped.
Regulatory position last checked: September 2026. If you are reading this much later, check the dates before you rely on them.
