The sixteen themes of the AAIF governance working group, read against binding law

About this documentUpdated 15 October 2026ShowHide

Sean McDermott, Co-Founder and CEO, UnGovr

Written by Sean McDermott (with AI assistance) using the LexLint law library, which supplied every legal instrument, status and date on these pages.

Every law named here links to its summary page on lexlint.io, translated to English (if needed) and restructured to a standard format for human and code use. Every case links to the court's or the regulator's own record where one could be reached.

© 2026 UnGovr, publishing as LexLint. The text and the figures are licensed under Creative Commons Attribution-ShareAlike 4.0: share and adapt them, including commercially, with credit to LexLint (UnGovr) and under the same license. Please contact LexLint at hello@ungovr.org to discuss other terms. Logos and wordmarks belong to their owners.

Law library as of 6 November 2026.

Legal information, not legal advice. This document describes the law as written and dated; it does not apply it to any system. The notice in the footer says what that means.

The Agentic AI Foundation's Governance, Risk and Regulatory Alignment working group extracts requirements from frameworks under sixteen themes. This page reads the same themes against the LexLint law library: how each of the law library's twenty obligation classes maps onto them, what the distribution says about where statutes speak and where they do not, and which handbook documents bear on each theme and each of the group's three deliverables.

1What this is

The Agentic AI Foundation (AAIF), a Linux Foundation foundation, runs a Governance, Risk and Regulatory Alignment working group whose charter sets three deliverables: a landscape of agentic-AI policy frameworks, a gap analysis, and distilled recommendations. Its monthly reports record the method it chose: common themes, and extraction prompts to map frameworks, standards and legislation onto them consistently. The July 2026 report, submitted on 2 August, records a general consensus on about a dozen themes. The August report, submitted on 3 September, lists sixteen, each with a short description, as the baseline for the gap analysis. In August 2026 the group also circulated a workbook to its members: an extraction prompt for each theme, to be run against one framework document at a time, and a reference guide of thirty frameworks to run them against. The workbook is not public; the themes are summarized here in the group's own words.

The sixteen themes are one of many groupings in use for AI governance and AI law, and each framework organizes risks and controls its own way. LexLint's frameworks pages read the laws LexLint tracks against ten of them, control by control, each control with the laws that bear on it:

• AI governance: NIST AI Risk Management Framework, NIST Generative AI Profile, OWASP Top 10 for LLM Applications, OWASP Top 10 for Agentic Applications, FINOS AI Governance Framework, ETSI EN 304 223, Baseline Cyber Security Requirements for AI Models and Systems.
• Privacy: NIST Privacy Framework.
• Security: NIST Cybersecurity Framework, CIS Critical Security Controls, ENISA NIS2 Technical Implementation Guidance.

Two more in use are not read there: the international standard ISO/IEC 42001 organizes the management of AI its own way, and AIUC-1, from the Artificial Intelligence Underwriting Company, is a controls standard for AI agents. None is the right grouping in the abstract; this page reads the group's sixteen against the law because the group agreed them as its baseline.

The prompts share one contract: classify every provision by type, decompose compound statements into atomic requirements, keep the exact modal language, and record for each requirement an identifier, the text, the type, the obligation strength, the applicable entity, the source clause and a confidence. Two of the prompts' rules matter most: do not infer applicability beyond what the source states, and say "legal interpretation required" where legal analysis is needed.

This page reads the same sixteen themes against a different source. Instead of thirty frameworks, the input is binding law by jurisdiction: the 15,417 requirement lines the LexLint law library carries for every AI, privacy, scraping and cybersecurity instrument it holds, each one already atomic, already tied to a citation, and already dated. The law library has an axis of its own for those lines: twenty obligation classes, a closed list LexLint defined in September 2026 so that findings group by the duty rather than by the statute's name, recorded on each instrument by the research. The requirement register in the handbook is keyed on it. The bridge between the two is a rule: a line joins a theme when its instrument's class is one the theme's prompt is about, or when the line's own wording matches the theme's key concepts. Section 2 prints that bridge in both directions, section 3 says what the result shows, and sections 4 and 5 say which handbook documents bear on each theme and each deliverable. The sixteen AAIF themes, one by one holds each theme's counts and a sample of its lines.

2The crosswalk

One row per obligation class, largest first. The Feeds outright column names the theme the class feeds outright, where a theme's prompt is about that class; the last column names the other themes that admitted at least a quarter of the class's lines by wording, which is where the overlap between the themes shows. Since the theme rules are generous, a line sits in 80% of cases in two or more themes, and a theme's count is an upper bound on what a careful reader would keep. 459 lines fall under no theme at all; they are in the handbook's register and its file, and absent from the theme file. The share column is a class's lines as a share of all 15,417 lines; a line counts under every class its instrument carries, so these shares add up to more than 100%.

The same bridge from the themes' side: for each theme, the classes its lines carry, largest first, and how many of its lines come from an instrument with no class recorded, which is the share of the theme that rests on wording alone. The share column is a theme's lines as a share of all 15,417 lines; a line can sit in several themes, so these shares also add up to more than 100%. The last column gives the count of no-class lines and, in brackets, their share of that theme.

3What the distribution says

Four themes carry most of the binding law: data protection and privacy (5,543 lines in force), security and access controls (6,310), transparency and USER disclosure (6,354) and recordkeeping and auditability (6,981). These are the themes where a statute, rather than a framework, is the source of the requirement, and they are where a gap analysis against binding law will find the most to measure.

Three themes are thin, and the thinness is the finding. Architecture has 82 lines, testing and red teaming 149, monitoring and logging 702. Binding law rarely tells an OPERATOR how to structure a system, how to test it, or what to log in what format; it tells the OPERATOR what outcome to secure and what record to be able to produce. Those three themes are framework territory, and the frameworks in the group's reference guide are the right source for them. What a statute adds is the outcome the framework control has to serve, which is why the recordkeeping theme is large while the logging theme is small.

Use-case classification and risk tiering (2,798 lines) is dominated by prohibitions: the law's way of tiering is to name what may not be done at all. Human oversight (355) and action management (213) are small but spread across many jurisdictions (140 and 107 respectively), which is the pattern of a duty that arrives through privacy law's automated-decision rules rather than through an AI statute. Incident response (2,585) is almost entirely breach notification, the oldest and most uniform family in the LexLint law library.

The themes and the classes are not two names for one thing. A theme is a family of controls an organization might adopt; a class is a family of duties a statute imposes. Where the two coincide, as with breach notification and incident response, the crosswalk is one row. Where they do not, as with architecture, the theme has almost no law under it and the class has no theme that is about it, and each side of the table says so in its own terms.

4Where the handbook reads each theme

The handbook at lexlint.io/agents is written for people building and running agents and is organized by their questions, not by the themes. This table says, for each theme, which of its documents carry the material a reader mapping that theme would want, and why. Each entry is the document's number in the handbook and its short name.

5The group's three deliverables, and where LexLint's pages bear on each

The charter names three deliverables. The handbook was not written for them or from the charter: it draws on several sources, among them the law library's own research of statutes and enforcement decisions, and it is organized by its readers' questions. Where its documents bear on a deliverable, they are listed here with the reason each is named. The frameworks pages sit outside the handbook and bear on the first; they follow its documents, unnumbered.

6The files

Three files are cut from the same lines on the date in this page's byline, and all three will be regenerated when the law library moves. The crosswalk counts every line; the two per-line files are a sample.

• theme-crosswalk.csv: the two tables in section 2 as one file, a row per obligation class with its counts, the theme it feeds outright, and how many of its lines each of the sixteen themes admits, with a last row for the lines whose instrument records no class.
• theme-register.csv: a sample, the requirement lines of European Union law that fall under at least one theme, one row per line, with the theme identifiers first and then the columns the prompts' contract asks for, plus the party, hook and tier columns the law library adds. Its columns are described on the sixteen themes, one by one.
• requirement-register.csv: a sample of the handbook's register, the lines of European Union law on the law library's own axes with the obligation classes and no theme columns, described in the requirement register.

theme-crosswalk.csv is licensed separately from the text and figures around it, under Creative Commons Attribution 4.0 rather than the ShareAlike terms in the byline: use it for any purpose, including commercially, with credit to LexLint (UnGovr). The other two files carry the same terms where they are offered: theme-register.csv in section 3 of the sixteen themes, and requirement-register.csv in section 6 of the requirement register.

7What this page does not claim

It does not say that any line binds any particular organization. That is the applicability question, and it is answered per deployment from the roles a system holds and where its parties are, which is what the first documents of the handbook are about. The theme assignment is a rule applied to text, reviewed in samples, not a finding made line by line, and the crosswalk is a description of where that rule put the lines, not a proposal that the themes or the classes be changed. Every entry, on these pages and in the files, links to the source the law library researched it from, so that the rule can be checked against the law.