A federated architecture for sector-led AI governance: lessons from India

Avinash Agarwal, Manisha J. Nene
3/27/2026
cs.CYcs.AIcs.HC

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Abstract

Purpose: India has adopted a vertical, sector-led AI governance strategy. While promoting innovation, such a light-touch approach risks policy fragmentation. This paper aims to propose a cohesive "whole-of-government" architecture to mitigate these risks and connect policy goals with a practical implementation plan. Design/methodology/approach: The paper applies an established five-layer conceptual framework to the Indian context. First, it constructs a national architecture for overall governance. Second, it uses a detailed case study on AI incident management to validate and demonstrate the architecture's practical utility in designing a specific, operational system. Findings: The paper develops two actionable architectures. The primary model assigns clear governance roles to India's key institutions. The second is a detailed, federated architecture for national AI Incident Management. It addresses the data silo problem by using a common national standard that allows sector-specific data collection while facilitating cross-sectoral analysis. Practical implications: The proposed architectures offer a clear and predictable roadmap for India's policymakers, regulators and industry to accelerate the national AI governance agenda. Social implications: By providing a systematic path from policy to practice, the architecture builds public trust. This structured approach ensures accountability and aligns AI development with societal values. Originality/value: This paper proposes a detailed operational architecture for India's "whole-of-government" approach to AI. It offers a globally relevant template for any nation pursuing a sector-led governance model, providing a clear implementation plan. Furthermore, the proposed federated architecture demonstrates how adopting common standards can enable cross-border data aggregation and global sectoral risk analysis without centralising control.

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Cite this paper

@article{agarwal2026federated,
  title  = {A federated architecture for sector-led AI governance: lessons from India},
  author = {Avinash Agarwal and Manisha J. Nene},
  year   = {2026},
  eprint = {2603.26865},
  archivePrefix = {arXiv},
  url    = {http://arxiv.org/abs/2603.26865v1}
}

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