Writing from the Fractional Chief AI Officer practice.
Governance material written for the people who carry the risk: managing directors, boards, and the operators who have to make an AI policy work on a Tuesday morning. No predictions, no vendor commentary.
21 pieces, read in any order.
Together they cover what the role is and what it costs, what the controls are, how to write the policy and vet the vendors, who regulates what in the UAE and the financial free zones, and how a board should interrogate all of it.
Keeping personal data to train AI in ADGM: section 31(4)(c) of the Data Protection Regulations 2021
The ADGM Data Protection Regulations 2021 mention artificial intelligence once: an exception that lets a firm keep personal data that is part of a dataset used to lawfully train or refine an AI system. What it requires, the impact assessment that must come first, and what it does not cover.
9 min read
RegulationWriting the AI notice under DIFC Regulation 10.2.2
Regulation 10.2.2 requires a notice at first use when an application or website service uses an AI system to process personal data. What paragraphs (a) and (b) say it must contain, and what paragraphs (c) to (g) leave on file instead.
9 min read
RegulationThe DIFC Annual Assessment and AI: what Article 19 asks a DPO to report
Where a DIFC Controller must appoint a DPO, Article 19 requires the DPO to assess its processing at least once a year, and the Controller to indicate whether it intends High Risk Processing in the following annual period. Where AI tools fit in, and what the form asks about them.
8 min read
RegulationThe DIFC impact assessment for an AI tool: what Article 20(6) requires
Article 20 of the DIFC Data Protection Law requires an impact assessment before High Risk Processing. Its five minimum contents, read against Regulation 10 for an AI tool.
9 min read
RegulationWho needs an Autonomous Systems Officer under DIFC Regulation 10?
The ASO is one of four conditions in Regulation 10.3.3, not a role every DIFC firm must fill. Four questions decide whether a firm needs one.
8 min read
RegulationThe DIFC High Risk test for AI: four limbs, and the one an AI risk review can overlook
The definition that decides whether a DIFC firm needs a DPO, a prior impact assessment and the Regulation 10 conditions, read word for word.
8 min read
The RoleWhat does a Fractional Chief AI Officer actually do?
The mandate, the first 90 days, and how a fractional appointment compares with a full-time hire.
7 min read
ChecklistAn AI governance checklist for UAE companies
Twenty-eight practical control points across inventory, policy, data, vendors, oversight, incidents, reporting and training.
9 min read
LandscapeWho regulates AI for a UAE company in 2026
National strategy, data protection law, free-zone regimes, sector regulators, voluntary standards and the reach of the EU AI Act.
8 min read
Board AgendaTwelve questions boards should ask about AI
A board-ready question set, each paired with what a credible management answer sounds like.
8 min read
CostWhat a Fractional Chief AI Officer costs in the UAE
The three engagement shapes, what moves the price, how it compares with a permanent hire, and what the first 30 days should produce.
8 min read
PolicyHow to write an AI acceptable-use policy for a UAE company
The ten clauses the document needs, how to word them, how it sits with your data protection regime, and how to make staff read it.
9 min read
ProcurementTwenty questions to ask an AI vendor before you sign
A generic due-diligence set across data handling, model provenance, security, monitoring and exit, each with what a good answer sounds like.
9 min read
Free ZonesAI governance for DIFC and ADGM companies
What the free-zone data protection regimes mean for AI use, where the financial regulator sits, and how the work differs from a mainland company.
8 min read
Sector: HealthcareAI governance for UAE clinics and healthcare groups
Where AI already sits in a clinic, why patient data raises the stakes, and where the line falls between administrative and clinical use.
7 min read
Sector: Real EstateAI governance for UAE real-estate brokerages
Lead automation, AI-written listing copy, valuation tools and the client documents sitting in agents’ personal accounts.
7 min read
Sector: Financial ServicesAI governance for UAE banks, payment firms and fintechs
Credit and onboarding decisions, fraud monitoring, customer assistants, model risk and the supervisory conversation behind all of them.
7 min read
Sector: Public Sector SuppliersAI governance for companies selling to UAE government entities
How AI questions now arrive in tenders and vendor questionnaires, and how to answer them with evidence rather than assurances.
7 min read
Sector: Professional ServicesAI governance for UAE law, accounting and consulting firms
Client confidentiality tiers, the review rule for generated work product, engagement-letter wording, and the billing conversation nobody wants to have.
7 min read
Sector: Retail & HospitalityAI governance for UAE hotels, restaurant groups and retailers
Guest-facing assistants, embedded vendor features, camera analytics, profiling, dynamic pricing and the staff decisions models now touch.
6 min read
Sector: Aviation & TravelAI governance for UAE aviation-services and travel businesses
The line between commercial and safety-related use, passenger data, disruption assistants, and the AI questions airline and airport buyers now ask suppliers.
6 min read
UAE AI Governance Readiness Index 2026
A research study scoring UAE mid-market companies across five dimensions of AI-governance readiness. In preparation. Register interest to receive your organisation's pre-publication scorecard.
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