# AI Regulator Engagement Plan and Position Paper Template Engaging regulators and standards bodies before rules are final. An engagement map, a comment process from flagging to filing, a position-paper template, and an engagement log. **Who this is for:** The policy or government-affairs owner who wants the organization's experience to inform AI rulemaking. Source playbook: https://aigovernance.com/playbook/proactive-regulator-engagement --- ## Regulatory engagement map _The bodies worth engaging, the current relationship, upcoming opportunities, and the internal owner._ ### Template | Body | Relevance to us | Current engagement level | Upcoming opportunities | Internal owner | |---|---|---|---|---| | | | none / responsive / active / member | consultations, workshops, drafts open | | ### Worked example | Body | Relevance | Engagement level | Upcoming opportunities | Owner | |---|---|---|---|---| | EU AI Office | sets guidance we must follow | responsive (we answer consultations) | Art. 6(3) guidance consultation Q1; code of practice workshops | Head of Policy | | NIST (AI RMF / GenAI profile) | our control framework aligns to it | active (we submit comments) | profile revision comment window | AI Gov Lead | | ISO/IEC JTC 1/SC 42 | AI standards we adopt | member (one delegate) | WG meetings quarterly | AI Gov Lead | | State AG (CO) | enforces SB205 | none | rule implementation feedback | US Counsel | ### Acceptance criteria - The map covers regulators, standards bodies, and working groups relevant to the business. - Each has an internal owner and a realistic engagement level, not an aspirational one. - Upcoming consultation and comment windows are tracked with dates. --- ## Comment process document _How a consultation goes from noticed to filed, with review and approval built in._ ### Template > The workflow for responding to a consultation or request for comment. 1. **Flag:** monitoring surfaces an open consultation; the engagement owner logs it with the deadline 2. **Decide:** go / no-go on responding, based on relevance and capacity; recorded 3. **Assign:** a drafter and contributing subject-matter experts 4. **Draft:** against the relevant position paper; note where we deviate and why 5. **Review:** Legal for legal exposure; Comms for messaging; the executive sponsor for sign-off 6. **File:** submit before the deadline; capture the confirmation 7. **Log:** record in the engagement log; note any follow-up (meeting requests, hearings) ### Worked example **EU AI Office Art. 6(3) guidance consultation:** - Flagged 2026-11-02, deadline 2027-01-15. - Go decision: yes (directly affects our Resume Screener classification). - Drafter: Head of Policy; SMEs: AI Gov Lead, Employment Counsel. - Draft built on position paper PP-2 (high-risk scoping). - Review: Legal (2 rounds), Comms, GC sign-off 2027-01-08. - Filed 2027-01-10; confirmation archived. - Follow-up: requested a bilateral meeting; pending. ### Acceptance criteria - Every response goes through a recorded go/no-go decision. - Legal and executive sign-off happen before filing. - Filed responses and their confirmations are archived. --- ## Position paper template _Internal reference documents stating the organization's view on key AI governance questions, reused across engagements._ ### Template > One per major policy question. Kept current. The source for consultation responses and meetings. - **Question:** the specific policy issue - **Our position:** stated in two or three sentences - **Rationale:** the reasoning, grounded in our operational experience - **Evidence:** data or examples from our own systems that support the position - **What we are asking for:** the concrete outcome (a definition, a threshold, a safe harbour, a timeline) - **Counter-arguments and our response:** - **Approved by and date:** ### Worked example - **Question:** How should the Article 6(3) derogation for non-high-risk Annex III systems be scoped? - **Our position:** The derogation should turn on whether the system materially determines the outcome, not on the use-case label alone. A tool that ranks but does not filter, with mandatory human review of every case, should be able to qualify. - **Rationale:** Our screening tool influences recruiter attention order; recruiters review every application regardless. Treating it identically to an auto-reject system misallocates compliance effort. - **Evidence:** override rate 12%; 100% of applications are human-reviewed; adverse-impact ratio 0.88 under monitoring. - **What we ask for:** guidance that lists "does not replace or materially determine the human decision" as a qualifying factor, with documentation requirements. - **Counter-arguments:** "ranking still shapes outcomes" is fair, which is why we propose documentation and monitoring conditions, not a blanket exemption. - **Approved by:** GC + Head of Policy, 2026-11-20. ### Acceptance criteria - Each position is backed by evidence from the organization's own systems, not generic argument. - It states a concrete ask, not just a concern. - It is approved by Legal and the policy owner and kept current. --- ## Engagement log _A record of what was filed, attended, and submitted, for continuity and for demonstrating good-faith engagement._ ### Template | Date | Body | Activity | Reference / topic | Position paper used | Outcome / follow-up | Owner | |---|---|---|---|---|---|---| | YYYY-MM-DD | | comment filed / meeting / hearing / standard vote | | | | | ### Worked example | Date | Body | Activity | Topic | Position paper | Outcome / follow-up | Owner | |---|---|---|---|---|---|---| | 2026-09-30 | NIST | comment filed | GenAI profile revision | PP-4 (evaluation) | acknowledged; some language adopted in the next draft | AI Gov Lead | | 2026-10-15 | ISO SC 42 WG | meeting attended | AI management system standard | PP-1 | volunteered as an editor for one clause | AI Gov Lead | | 2027-01-10 | EU AI Office | comment filed | Art. 6(3) guidance | PP-2 | meeting requested, pending | Head of Policy | ### Acceptance criteria - Every engagement activity is logged with the topic and the position paper used. - Outcomes and follow-ups are captured, not just the submission. - The log is available to Legal and leadership as evidence of engagement. --- ## Governance controls this kit produces evidence for - **CMP-005**: The whole kit is the regulatory engagement process for AI standards development. - **CMP-002**: The engagement map and its opportunity tracking extend standards and regulatory monitoring into participation. - **BRD-004**: Position papers and the engagement log support ESG and investor disclosure on responsible AI leadership. - **CMP-003**: Engagement with voluntary frameworks and standards bodies is tracked alongside binding-rule monitoring.