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Texas Responsible AI Governance Act compliance: A sample policy framework

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Contributors:

Fatima Naeem

Attorney

Naeem Law Firm

Editor's note: The IAPP is policy neutral. We publish contributed opinion and analysis pieces to enable our members to hear a broad spectrum of views in our domains.

The Texas Responsible Artificial Intelligence Governance Act will take effect 1 Jan. 2026; it applies broadly to all businesses operating in Texas that use an artificial intelligence system in the state as well as companies whose products or services are used by Texas residents.

The TRAIGA targets AI systems, defined as "any machine-based system that, for any explicit or implicit objective, infers from the inputs the system receives how to generate outputs, including content, decisions, predictions, or recommendations that can influence physical or virtual environments." Its scope includes both the developer and deployer of the AI system. Businesses can use the following sample policy framework as a starting point for TRAIGA compliance.

Policy

Purpose. Provide a high-level description of the intended use, deployment, context and associated benefits of the AI system with which the business is affiliated.

Type of data. Offer a detailed description of the data used to program or train the AI system in use.

Categories of data. Classify the categories of data processed as inputs and produced outputs.

AIS performance evaluation. Establish metrics to evaluate the performance of the AI system. How will the business know if the AI system is doing what it is supposed to do? A recommended approach is to conduct performance evaluations semi-annually for the first two years and annually thereafter.

Contributors:

Fatima Naeem

Attorney

Naeem Law Firm

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