E · The operating model

Chapter 21. Roles, Decision Rights, and RACI

Who decides what, and the two role problems the framework has not solved.


21.1 The role catalogue

Table 56.

Role Accountable for Key authority Owns
Business Sponsor / Capability Owner Business value delivered Approve or reject use-case qualification Use-Case Canvas, Capability Record
AI / Enterprise Architect Architecture quality and pattern conformance Self-certify Tier 1–2 G2; author ADRs ADRs, pattern library
Data Owner Data classification and lineage accuracy Approve or reject data readiness Data Lineage and Sensitivity Records
AI / System Owner System behavior, conformance, retirement Responsible for evidence at every gate Configuration and change records
Risk and Compliance Lead Risk scoring accuracy, control effectiveness Assign and re-assign tier; countersign scores Risk Classification Records, Control Matrix
Security Architect Security posture of governed components Consulted at all gates; can block on unresolved findings Security control records
Procurement Vendor due-diligence evidence Consulted at S1–S2 for procured AI Vendor evidence records
Architecture Review Board Architecture conformance enterprise-wide Approves Tier 3–4 G2; ratifies patterns Approved pattern library
AI Governance Body Deployment authorization quality at Tier 3–4 Approves Tier 3–4 G3/G4; funding concurrence Deployment authorization records
Enterprise Governance Sponsor Framework integrity; cross-body conflict Ratifies principles; resolves conflicts Central principles
Transformation / PMO (external) Portfolio delivery outcomes Prioritization and funding Portfolio roadmap (external)

21.2 Decision rights by tier

Table 57.

Decision Tier 1 Tier 2 Tier 3 Tier 4
Approve architecture (G2) Architect self-certifies Architect self-certifies, ARB notified ARB ARB, Enterprise Sponsor briefed
Approve deployment (G3) System Owner System Owner, AI Governance Lead notified AI Governance Body AI Governance Body + Enterprise Sponsor
Approve a new foundation model for the enterprise list Architect proposes, ARB ratifies — applies once, enterprise-wide, not per tier
Change a system’s risk tier Risk Lead, self-service if downward or lateral Risk Lead; AI Governance Body notified if upward AI Governance Body AI Governance Body + Enterprise Sponsor briefed
Authorize or increase agent autonomy Not applicable; an increase re-triggers classification AI Governance Body AI Governance Body AI Governance Body + Enterprise Sponsor
Approve an exception System Owner, ≤ 90 days AI Governance Lead, ≤ 90 days AI Governance Body, ≤ 90 days, renewal requires re-justification AI Governance Body + Enterprise Sponsor, ≤ 90 days, no auto-renewal
Retire a system (G5) Owner + Data Owner Owner + Data Owner Adds AI Governance Lead Adds AI Governance Body
Accept residual risk System Owner AI Governance Lead AI Governance Body AI Governance Body + Enterprise Sponsor

The foundation-model row is deliberately not tier-differentiated. A model either joins the approved list or it does not; that decision is made once, centrally, not re-litigated by every use case that wants to use it.

21.3 The AI Build Lifecycle RACI

Table 58.

Stage / Gate Sponsor Architect Data Owner System Owner Risk Lead Security ARB AI Gov Body
S0–S1 Opportunity, Qualification R C C I I (T3–4)
S2 Risk Classification C C C A/R C I (T3–4)
G1 A C I R (T3–4) C (T3–4)
S3 Architecture I A/R C C I C C (T3–4)
S4 Data Readiness I C A/R C I C
G2 I R R C C C A (T3–4)
S5 Build / Acquire I C I A/R C
S6 Assurance I C I R A C
G3 I C I R (A at T1–2) A (T3–4) C A (T3–4)
S7 Deployment Authorization I I I R C C A (T3–4)
S8 Runtime and Monitoring I I I R A C I I (T3–4)
S9 Change I C C R C C I (Major, T3–4)
G4 I C C R A (T1–2) C C (T3–4) A (T3–4)
S10 Retirement I I A/R R C I C (T3–4)
G5 I I A R C I C (T3–4)

R responsible, A accountable, C consulted, I informed. Tier qualifiers make involvement conditional. Blanks indicate no defined involvement.

A deliberate design check is visible in this table: no role is accountable at more than roughly a third of stages, and the Enterprise Governance Sponsor is accountable nowhere. Making every senior leader accountable for everything is an anti-pattern the framework actively guards against.

21.4 Two unsolved role problems

Security Architect is consulted, never accountable. Across the entire RACI, the Security Architect advises and can block on unresolved findings, but is never the accountable party. Independent review found this under-weighted relative to security’s actual role in agent and coding-agent failure modes, and it remains an open gap.

[Practice recommendation] Elevate Security Architect to co-accountable with the Risk Lead at G3 for any system with agentic capability or external exposure. This departs from the specification, and you should record it as a local variation. The framework’s own limitations register flags this as a gap worth closing; closing it locally is defensible.

Procurement arrives late in most organizations. The role is named as consulted at S1–S2, but in practice purchasing decisions for AI-embedded software are frequently made outside the technology function entirely. Naming the role does not create the routing. [Practice recommendation] Add an AI-content question to the standard procurement intake and route any positive answer to S0, regardless of contract value. Value thresholds are the wrong filter, because embedded AI arrives in inexpensive software.