ARTICLE
26 January 2026

AI Governance: Adapting To AI Agents And Tech Democratisation

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A&O Shearman

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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
AI—the technology itself, its deployment and regulation—is evolving rapidly and organisations face mounting pressure to keep pace.
United Kingdom Technology
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AI—the technology itself, its deployment and regulation—is evolving rapidly and organisations face mounting pressure to keep pace. In this article, first published in the Privacy and Data Protection Journal, Emma Keeling, senior knowledge lawyer in our data and AI practice, and Steve Wood, former deputy commissioner at the ICO and data consultant at A&O Shearman, explore the evolution of AI governance.

They consider how businesses can implement AI swiftly and safely, particularly given the increasing democratization of the technology and the roll out of AI agents.

Having set the regulatory context, they examine how traditional governance structures are adapting to the need for greater decentralization and how organisations are approaching risk management and technical controls to support effective and compliant innovation.

Amongst other things, the article considers the need for ongoing engagement, scalability and an approach to performance indicators that offers relevant insight for management. They go on to ask what human oversight looks like in the context of AI agents, when the potential for AI-related risk may be amplified.

Download the full PDF to dive deeper into the authors' practical recommendations and future facing insight.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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