A policy is not a control
Most AI governance work produces documents: principles, usage policies, review boards. They tell people what is allowed. They do nothing when an agent at three in the morning is about to send a refund confirmation to the wrong customer. A control is different: it is a rule the workflow enforces. Governance that does not live inside the workflow protects the org chart, not the customer.
What a control set contains
Per workflow, five things. Permissions: which systems and fields the agent may read, and which it may write, in which status. Thresholds: the confidence and business limits below which a case goes to a person. Checkpoints: which outputs a named role must release, and which may go out alone after the shadow phase. Logging: inputs, sources, output, release, per case, retained as long as the business record. Escalation: what happens when the agent is unsure, out of scope, or receives something hostile.
Mapping to the EU AI Act and GDPR
Most operational agents in service, quoting or document processing fall into limited or minimal-risk categories under the EU AI Act, with transparency duties; where they touch decisions on employment or creditworthiness, high-risk obligations can apply. We are not lawyers, and the classification belongs to your compliance function. What the control set gives them is the material: a risk classification per workflow, documented data flows, human oversight where it applies, and logs. GDPR needs the same material: purpose, legal basis, data categories, retention. One set of documents, produced while building, not afterwards.
Shadow mode is the audit
Before an agent may act alone on any category of case, it runs in shadow mode against live cases: it drafts, a person decides, the two are compared. The comparison is the evidence for the release decision, and it is the evidence an auditor will ask for. Keep it.
Governance that speeds things up
Teams with a written control set move faster, because security, data protection and the works council know what has been decided and can read it in an hour. Teams without one negotiate every case from scratch. The control set is not the tax on the workflow. It is the reason the workflow is allowed to run.