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The ten-week engagement map. What you will build and in what order

The whole programme on one page. Four phases, four verbs, four checkpoints. Learn this shape before you learn a Sutra, because every operational decision in Weeks 1-10 is really a decision about which phase you are currently in.

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In July this year the newly appointed AI Governance Officer at Aarti Capital Markets sat in my office with an open laptop and a frustrated expression. He had read the SEBI Advisory of 5 May 2026, the MeitY Guidelines, the DPDP Act Section 10 and the FREE-AI Report. He understood each. He had no idea how to start on Monday. "What do I actually do in Week 1?" he asked.

A ten-week AI governance build is not a mystery. It has four phases, each with one verb and one deliverable set, bracketed by four Board or Audit Committee checkpoints. The shape has worked for me on a BFSI broker, a healthtech, a fintech and a GCC. It will work for you. If you cannot answer the question "which phase are we in and what verb is this week," you are drifting.

Phase 1 Weeks 1-2 Appoint

The verb is Appoint. The deliverables are the AI Governance Officer appointment Board resolution [L5-C1], the stakeholder RACI naming Accountable, Responsible, Consulted and Informed roles for each strand, the AI inventory and model register populated with every AI system currently in use or planned for the next quarter, and the Function Allocation Worksheet from Lesson 3.

You will not have a policy yet. You will not have a DPIA yet. You will not have testing or monitoring yet. That is correct. If you try to draft an AI governance policy on Day 3 before you know what AI systems you are governing, the policy will be redrafted four times by Week 5.

Phase 1 ends with Checkpoint 1, a short Board or Audit Committee meeting at the end of Week 2 that formally receives the appointment, the RACI, the inventory and the Function Allocation. Minutes are signed. The AI Governance Officer now has the authority to proceed.

Phase 2 Weeks 3-5 Draft

The verb is Draft. The deliverables are the twelve-clause internal AI governance policy, the AI DPIA template aligned to DPDP Section 10(2)(c) proviso and Rule 13 [L5-C2], the pre-deployment risk assessment checklist (bias, robustness, security), the model card template, the datasheet-for-dataset template, the user-facing AI transparency notice template under Sutra 6 [L5-C3], the human-in-the-loop oversight SOP, and the AI incident response runbook.

Phase 2 is also the right time to pause new high-risk AI go-lives for three weeks while the policy is drafted. The business will object. The right response is that the pause is for three weeks only, that it applies to high-risk use cases, and that go-live will resume at Checkpoint 2 under the new policy.

Phase 2 ends with Checkpoint 2, a formal policy-approval Board meeting at the end of Week 5. The policy is approved by resolution. The DPIA template is approved by the Audit Committee. The AI incident response runbook is signed off by the AI Governance Officer and the CISO. The go-live pause lifts the next morning.

Phase 3 Weeks 6-8 Operate

The verb is Operate. The deliverables are a trained team (AI product owners, data engineers, legal, compliance), a running DPIA pipeline with three practice DPIAs on real systems in the inventory, pre-deployment testing executed on at least two production models, post-deployment monitoring stood up with drift detection on at least two production models, and the first AI incident report trial-run through the response runbook.

Phase 3 is where most programmes break. The DPIAs take longer than planned. The pre-deployment testing surfaces findings nobody wants to address. The drift detection produces false positives for the first two weeks. Treat each as expected. Build a weekly operations review in Week 6. Hold a mid-phase retrospective in the middle of Week 7. Expect to adjust the DPIA template and the testing scope at least once before Week 8.

Phase 3 ends with Checkpoint 3, an internal operations review at the end of Week 8 that measures DPIA completion rate, pre-deployment-testing coverage of production models, drift-detection coverage and training completion. The AI Governance Officer signs the review.

Phase 4 Weeks 9-10 Review

The verb is Review. The deliverables are a mock MeitY/sectoral-regulator review run by an external advisor or by internal audit, a Board briefing deck summarising programme health in six slides, a twelve-month operating calendar covering monthly, quarterly, half-yearly and annual tasks, and the written handover package the AI Governance Officer owes a successor.

The mock review is non-negotiable. It costs a day of your advisor\'s time and reveals policy gaps the drafter did not know existed. By the time the first SEBI, RBI or DPB inspection arrives, you will have closed them.

Phase 4 ends with Checkpoint 4, a full Board sign-off at the end of Week 10. The Board receives the six-slide health deck, the operating calendar and the risk register. The Audit Committee adopts the twelve-month calendar. The engagement is now programme, not project.

Three programme killers to disarm in Week 2

Unclear AI Governance Officer authority. If the appointment resolution is silent on the authority to pull a model out of production, Phase 2 drafting becomes a negotiation. Fix this in the resolution.

No AI inventory. If you cannot list every AI system in use in the organisation on one page by end of Week 2, the DPIA pipeline in Phase 3 has nothing to run on. Fix this at Checkpoint 1.

No go-live posture agreed. If the business and the AI governance function enter Phase 2 with different assumptions about whether high-risk new deployments continue, every policy decision becomes a fight. Fix this in Week 2 with a written three-week go-live posture.

Five failure modes on sequencing

Trying to run all four phases in parallel. The phases are sequential for a reason. Appointment unlocks authority. Authority unlocks drafting. Drafting unlocks operation. Operation unlocks review. Skip a step and the next step has no foundation.

Over-scoping the first programme. Keep the first ten weeks tight. Add deeper topics (GenAI red-teaming, formal fairness methods, international compliance alignment) in the next quarter.

Under-training product owners. The policy that lives only in the AI Governance Officer\'s laptop is theoretical. Phase 3 training is where it becomes working.

Letting drift detection produce noise. Scenario-tune twice. Agree a daily or weekly review window. Document the closed alerts for the due-diligence defence.

No calendar after Week 10. The programme must run forever. Checkpoint 4 is the start, not the end.

Your artifact from Lesson 5

Draw the ten-week engagement map for your organisation on one page. Four phases, four verbs, four checkpoints, with the deliverables and owners for each. Save it as Artifact 5 in your capstone workbook. We will revisit this map at the end of each module as a cross-check against drift.

The 2-click version

You have three honest routes to deliver the ten-week programme on your organisation. Route one is to run the course templates manually with your in-house team using the artifacts you build across Modules 1-12. The templates are complete and the engagement is doable with a two-person team. Route two is to run the programme inside the dcomply Compliance Suite, which pre-wires the capstone artifacts (policy, DPIA, model card, incident runbook, calendar) as live tools rather than Word documents. Route three is to engage Decipher done-for-you, where our team runs the Appoint-Draft-Operate-Review cycle on your organisation with you reviewing at each checkpoint. The certificate is the same on all three routes.

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Citations
MeitY AI Governance Guidelines 2025, Sutra 5 Accountability (Sutra 5) L5-C1
Accountability follows function. Developer, deployer and data provider each answer for their own choices.
DPDP x AI, DPDP Rules 2025 Rule 13 (DPDP Rule 13) L5-C2
Additional obligations for Significant Data Fiduciary including DPIA every twelve months and periodic independent audit.
MeitY AI Governance Guidelines 2025, Sutra 6 Understandable by Design (Sutra 6) L5-C3
Disclosures and explanations the intended user and regulators can actually understand.
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Reading Module 1. Enrol to unlock the rest of the course.
Module 1: The India AI Governance Perimeter and Why You Are Reading This
Module 2: The MeitY Guidelines, Section by Section
  • The 7 Sutras, one by one, with the Indian context behind each
  • The 6 Pillars across Enablement, Regulation and Oversight, and the two Pillars where you actually spend time
  • Developer, deployer, data provider. Three functions, three parallel sets of duties documented, signed and defended
  • Transparency reporting under Sutra 6, aligned to DPDP, and what a disclosure a regulator can understand actually looks like
  • AIGG, TPEC and AISI. The three institutions, the current state on 9 October 2026 and how to track
Module 3: RBI FREE-AI and Financial-Sector AI
  • The FREE-AI Committee, the Report of 13 August 2025 and the 26 Recommendations that preceded MeitY
  • The Model Risk Management Framework. RBI Draft of 5 August 2024 and the expanded 2026 cycle
  • AI in credit underwriting. Borrower scoring, bias testing and challenger models at an NBFC gold-loan and personal-loan book
  • The AI kill-switch and incident reporting. FREE-AI expectations, the Chapter 5 form and the CERT-In six-hour interface
  • The Bank and NBFC Board policy on AI. The twelve-clause specimen outline
Module 4: SEBI AI Vulnerability Advisory and Market Infrastructure
  • The SEBI AI Vulnerability Advisory of 5 May 2026. HO/13/19/12(1)2026-ITD-1_CIMGI/10873/2026
  • Annexure A, ten items. The deep walk through items 2, 6c, 9 and 10
  • Market SOC onboarding. What M-SOC is, what it ingests and how an entity integrates
  • How the AI Advisory expands CSCRF audit scope. project-cyber-suraksha.ai and advisor obligations
  • Running the SEBI AI programme end-to-end on Aarti Capital Markets
Module 5: DPDP x AI
  • Section 10 Significant Data Fiduciary. The six-factor test and why nobody has been notified yet
  • Section 10(2)(c) proviso. Algorithmic due diligence, verbatim text and operational meaning
  • Rule 13. Twelve-month DPIA, independent audit and the Board reporting cadence
  • Rule 7 breach notification. AI incidents, the DPB clock, the MeitY expectation and the CERT-In six-hour window
  • Why DPDP has no Article 22. India chose a de facto automated decision regime through Section 10(2)(c)
Module 6: The AI Governance Officer's Playbook
  • The appointment Board resolution in detail. Five authorities, eleven paragraphs, one specimen
  • The AI inventory and model register. Columns, worked rows, and the "one-page in thirty minutes" test
  • The twelve-clause AI governance policy. Scope to third-party management, one clause at a time
  • The Board reporting cadence and the five KPIs that matter
  • Personal liability and the due-diligence defence. DPDP Schedule, sectoral penalties, Section 79 safe harbour
Module 7: Risk Assessment, DPIA and the Model Lifecycle
  • High-impact decision classification. The method MeitY left to you
  • The AI-specific DPIA. Ten sections that satisfy DPDP Section 10(2)(c) and Rule 13
  • Pre-deployment testing. Bias, robustness and security batteries that satisfy a regulator
  • Post-deployment monitoring. Drift, feedback loops, shadow mode and the thresholds that trigger review
  • Change control, retraining and incident response. Closing the lifecycle loop
Module 8: Transparency, Explainability and Human Oversight
  • User-facing transparency notices. Operationalising Sutra 6 for Aarti Capital's three AI use cases
  • Model cards and datasheets for datasets. The two documents a regulator will ask for first
  • Explainability for high-impact decisions. What SHAP, LIME and counterfactuals buy you, and where they fail
  • Human-in-the-loop oversight. Three stages, one SOP, and how to document that a human actually reviewed
  • Audit trail and immutable logging. Reconstructing a specific AI decision three years later
Module 9: Synthetic Media and the IT Rules 2026 Amendment
  • The new Synthetically Generated Information category under the IT Rules 2026 amendment
  • Labelling and provenance metadata. Watermarks, C2PA and metadata that survives re-encoding
  • The three-hour takedown and the two-hour non-consensual sexual imagery window
  • Deepfake case law. Rashmika Mandanna, Lok Sabha 2024 and Images Bazaar PIL
  • The MeitY advisories of 1 March and 15 March 2024. How India iterates fast
Module 10: Sectoral Deep-Dives: IRDAI, Telecom, Health and Public Services
  • IRDAI AI Working Group and the framework insurers should pre-build
  • The IRDAI 2026 Cyber Security Guidelines and AI as a threat vector
  • The Telecom Cyber Security Rules 2024 and where AI sits in a silent framework
  • TRAI's AIDAI proposal and why MeitY picked AIGG, TPEC and AISI instead
  • Healthcare, education and public-services AI: the gaps and the practitioner playbook
Module 11: The International Reference Layer
  • EU AI Act. The four risk tiers and the phased timeline that quietly binds Indian GCCs
  • NIST AI RMF 1.0 and the GenAI Profile. Four functions and twelve generative risks
  • OECD AI Principles. The common vocabulary that lets a Mumbai team talk to a Munich team
  • ISO/IEC 42001. The voluntary conformity path and the clause-by-clause map to the MeitY 7 Sutras
  • The GCC compliance architecture. One baseline plus two overlays, when EU plus India plus US arrives at once
Module 12: Capstone and Final Exam
  • Build your ten-week AI governance programme. The scope document and the stakeholder map
  • Weeks 1-10 Gantt and the twelve artifacts of the capstone workbook
  • The Board briefing deck and the year-1 operating calendar
  • The 25-anchor exam reference card
  • The final exam. 45 questions from a 70-item pool, 90 minutes, 75 percent pass