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AI Governance for SMEs: Using IMDA's Framework and AI Verify

Singapore has no general AI law for businesses. Instead, IMDA publishes voluntary Model AI Governance Frameworks, for traditional AI, generative AI and, since January 2026, AI agents, plus the AI Verify testing framework. They are written for large organisations, but the core ideas fit on one page. This guide explains what each framework covers, which parts matter for an SME using a chatbot or AI tools, and gives a checklist you can complete in an afternoon.

By IT SortedUpdated 7 min read
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Key takeaways

  • IMDA's Model AI Governance Frameworks are voluntary guidance, not law.
  • The generative AI framework, released 30 May 2024, sets out 9 dimensions including accountability, data and security.
  • A framework for agentic AI launched on 22 January 2026 and was updated in May 2026.
  • AI Verify has 11 principles with process checks and a free Excel checklist.
  • IMDA's Starter Kit lists five LLM risks to test, including hallucination and data leakage.
In this guide · 8 sections
  1. 01Singapore's AI governance frameworks at a glance
  2. 02What the frameworks ask for, in plain English
  3. 03The one-page AI governance checklist for SMEs
  4. 04How to test an AI chatbot before launch
  5. 05Is AI Verify worth it for a small business?
  6. 06Where the PDPA fits
  7. 07Do it yourself or get help?
  8. 08Frequently asked questions

Short answer

For a small business, AI governance means four things: name a person accountable for each AI tool, control what data goes in, test it before customers see it, and tell people when they are dealing with AI. IMDA's frameworks are voluntary, but they are Singapore's reference point.

Singapore's AI governance frameworks at a glance

Four documents form the core. All are free and voluntary, and most are hosted on the AI Verify Foundation resources page.

FrameworkReleasedWhat it covers
Model AI Governance Framework (traditional AI)2019; second edition 21 Jan 2020Four areas: internal governance, human involvement in decisions, operations management, stakeholder communication
Model AI Governance Framework for Generative AI30 May 2024Nine dimensions, from accountability and data to security and content provenance
Model AI Governance Framework for Agentic AI22 Jan 2026, updated May 2026Four dimensions for AI agents that take actions on your behalf
AI Verify Testing Framework2022, mapped to ISO/IEC 42001 in 202511 principles with process checks and evidence to collect

If you only read one, read the generative AI framework, because that is what most SME chatbots and writing tools are. If you are letting an AI agent send emails, book appointments or update records by itself, add the agentic framework.

What the frameworks ask for, in plain English

Strip out the parts aimed at model developers and governments, and the frameworks ask a business deploying AI to do a handful of things.

  • Accountability: someone in the business owns each AI system and answers for it. The agentic framework says humans remain ultimately accountable, even when an agent acts on its own.
  • Data: know what data goes into the tool, keep personal data to the minimum, and follow the PDPA.
  • Human involvement: decide how much a person checks before the AI's output reaches a customer. The traditional framework describes this as human-in-the-loop, human-over-the-loop or human-out-of-the-loop, based on how serious and likely the harm is.
  • Testing: check the tool works and is safe before launch, and keep checking.
  • Incident reporting: have a way to notice, fix and record when the AI gets something wrong.
  • Transparency: tell customers when they are dealing with AI and how to reach a human.

For AI agents, the January 2026 framework adds two practical rules: limit what an agent can access and do from the start, and define 'significant checkpoints' where a person must approve before it acts.

The one-page AI governance checklist for SMEs

Complete this for each AI tool that touches customers or personal data, such as a website chatbot, an AI email assistant or an automation that drafts replies.

AI governance checklist (one tool per sheet)

Keep the completed sheets with your PDPA records. Our PDPA checklist for small businesses shows where they fit alongside your data inventory and privacy notice.

How to test an AI chatbot before launch

IMDA's Starter Kit for testing LLM-based applications is voluntary guidance for pre-launch testing. It names five risks to test for: hallucination and inaccuracy, bias in decision-making, undesirable content, data leakage and vulnerability to adversarial prompts. An SME version of its identify, test, assess approach looks like this.

  1. Identify the risks that matter

    For a shop or clinic chatbot, the big ones are wrong prices or policies (hallucination) and revealing other customers' details (data leakage).

  2. Write test questions with known answers

    Use 20 to 30 real customer questions, including tricky ones, and write down the correct answer for each.

  3. Try to break it

    Ask it to ignore its instructions, reveal its system prompt, quote a discount that does not exist or give medical or legal advice.

  4. Set a pass mark

    For example: no wrong prices, no personal data shown, and a hand-off to a human for anything outside its scope.

  5. Fix, retest and save the results

    Adjust the instructions or knowledge base, rerun the same questions and keep the results as evidence.

Repeat the same test when you change the AI model or vendor. Several models are being retired this quarter, as our Q4 2026 AI model roundup explains.

Is AI Verify worth it for a small business?

AI Verify is a testing framework and an open-source toolkit. The framework has 11 principles, including transparency, safety, security, fairness, data governance, accountability and human oversight, each with process checks and the evidence to collect. The Foundation offers the checks as a PDF, an Excel checklist and, for generative AI, a software tool that produces a summary report.

Use the AI Verify checklist if

  • A corporate customer or tender asks how you govern AI
  • You build your own AI product for clients
  • You want to show alignment with ISO/IEC 42001
  • AI makes decisions about people, such as screening applicants

The one-page checklist is enough if

  • You use AI to draft emails and documents
  • Your chatbot only answers FAQs from your own content
  • A person reviews every AI output before it goes out
  • You have fewer than about 20 staff and one or two AI tools

The Excel checklist is a useful reference even if you never complete it. Reading the transparency and data governance checks gives you a good list of questions to ask an AI vendor.

Where the PDPA fits

The frameworks are voluntary, but the PDPA is not. If your AI tool uses personal data, the usual obligations apply: consent or another legal basis, purpose limitation, protection, and care when data goes overseas. The PDPC has also issued advisory guidelines on personal data in AI recommendation and decision systems.

Our guide to AI chatbots for your website covers the PDPA points for chatbots, and is DeepSeek or Qwen safe for business covers overseas data transfers. This is general information, not legal advice.

Do it yourself or get help?

An owner can complete the one-page checklist for two or three AI tools in an afternoon. The testing step takes longer if you have never done it, but the five-step routine above is enough for a FAQ chatbot.

AI Website Assistant (S$790) sets up a website chatbot on your own accounts, with a pre-launch test, a visible AI notice and a hand-off to a human. PDPA Compliance Pack (S$690) produces your privacy policy, data inventory and staff data protection policy, where your AI records belong. IT Sorted is not a law firm and does not give legal advice.

Frequently asked questions

Not a general one, as of October 2026. Singapore relies on voluntary frameworks from IMDA, such as the Model AI Governance Frameworks and AI Verify, together with existing laws like the PDPA. Some sectors have their own guidance, so check with your regulator if you are in finance or healthcare.

It is a voluntary framework from IMDA and the AI Verify Foundation, released on 30 May 2024. It sets out nine dimensions for a trusted generative AI environment: accountability, data, trusted development and deployment, incident reporting, testing and assurance, security, content provenance, safety and alignment research, and AI for public good.

AI Verify is Singapore's AI governance testing framework and open-source toolkit, run by the AI Verify Foundation. The framework covers 11 principles, such as transparency, safety, fairness and accountability, with process checks and evidence to collect. It is mapped to international frameworks including ISO/IEC 42001 and the US NIST AI Risk Management Framework.

It is not mandatory. It is useful because customers, tenders and insurers increasingly ask how you manage AI, and the framework gives you a recognised structure for the answer. A one-page record per AI tool covering owner, data, testing and transparency is a practical way to apply it.

IMDA launched the Model AI Governance Framework for Agentic AI on 22 January 2026 and updated it in May 2026. It covers AI agents that plan and act on a user's behalf, and recommends bounding risks upfront, human approval at significant checkpoints, technical controls across the agent's lifecycle and end-user transparency.

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