On 22 January 2026, Singapore’s Infocomm Media Development Authority (“IMDA”) published the Model AI Governance Framework for Agentic AI (the “MGF”). The MGF is the world’s first comprehensive governance guide specifically designed to address the risks of agentic AI.
As with all of Singapore’s previous guidance on AI, the MGF is a voluntary framework. However, alignment with the framework can support organisations with managing legal exposure and regulatory risks. This is because organisations deploying AI still ultimately remain accountable for the actions of and impacts caused by their AI use cases under existing laws.
Background: Singapore’s promotion of responsible AI use
In line with its focus on “AI for the Public Good”, Singapore has continuously developed guardrails and frameworks to promote responsible AI use and governance. Some examples of recent guidance issued by various government bodies in Singapore include the:
- Model AI Governance Framework introduced in 2019 to provide readily implementable guidance to address key ethical and governance issues in AI deployment; and
- Model AI Governance Framework for Generative AI released in 2024 to address generative AI-specific risks and considerations – Please read our previous article available here to learn more.
The release of the MGF continues a clear trajectory in Singapore’s rapidly evolving, multi-layered AI governance landscape.
What is agentic AI and how does it affect your organisation?
Agentic AI refers to systems that use one or more AI agents over multiple steps to achieve a user-defined goal.
Unlike traditional AI and generative AI, AI agents can plan, reason and act independently to complete tasks on behalf of users. This allows organisations to automate repetitive tasks, and enhance operations in areas such as customer service, supply chain optimisation, predictive logistics and fraud detection.
As organisations leverage the greater capabilities of agentic AI, they should also be mindful that the increased autonomy also brings heightened risks. As identified in the MGF, these include:
- Erroneous actions: An agent may produce incorrect actions, such as scheduling appointments on the wrong date or making accidental payments;
- Unauthorised actions: An agent may act beyond its permitted scope or authority, such as taking an action without escalating it for human approval;
- Biased or unfair actions: An agent may make decisions leading to unfair outcomes, such as hiring on a discriminatory basis;
- Data breaches: An agent’s acts may lead to the exposure or manipulation of sensitive data (e.g. personal information and confidential data); and
- Disruption to connected systems: An agent may disrupt connected systems when it is compromised or malfunctions.
These risk areas may be particularly acute for certain organisations, including:
- financial institutions and payments providers handling sensitive financial or transactional data;
- healthcare providers and their vendors that process medical or patient data;
- technology companies and AI developers with access to large, diverse datasets for algorithmic training; and
- back end or outsourced service providers supporting any of the above entities.
For these organisations, the operational and data access capabilities of agentic AI can elevate exposure to privacy, cybersecurity, and systemic impact risks, and give rise to potential regulatory or contractual liability.
The MGF addresses these risks, as reflected in our high-level summary below:
Overview of the MGF
The MGF builds on the Model AI Governance Framework and outlines emerging best practices in agentic AI deployment. All organisations deploying or intending to deploy agentic AI (whether through in-house development or outsourcing third-party agentic solutions) are encouraged to adopt the suggested measures for responsible use.
Recommended technical and non-technical measures in the MGF span four dimensions:
| Dimension |
Guidance |
| 1. Assess and bound the risks upfront |
Evaluate each use case for agentic AI deployment
Organisations should identify and assess risks, considering the likelihood of risks and severity of impact. Factors that should be considered include the:
- level of tolerance for error in the concerned domain and use case;
- agent’s access to sensitive data;
- agent’s access to external systems;
- reversibility of the agent’s actions;
- agent’s level of autonomy; and
- complexity of the task.
Use design limits to put guardrails around risks
Limits may be defined for the agent’s access to tools and systems, autonomy, and area of impact. Examples of some design limits that can be implemented by organisations include:
- identity management and access control measures to track individual agent behaviour and allocate accountability;
- linking an agent’s identity to a supervising agent, human user or organisational unit; and
- ensuring that the agent’s permissions do not exceed those of a human user.
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2. Make humans meaningfully accountable
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Clearly allocate responsibilities within and outside the organisation
Accountability for the decisions and outcomes of agents should be flowed down the value chain.
Within the organisation, responsibilities should be allocated across teams, e.g.:
- Board members and senior management should set high-level goals and permissions for agents, and manage the overall governance approach.
- Product teams should define the requirements of agents and ensure that agents are implemented responsibly throughout their lifecycle.
- Cybersecurity teams should define baseline guardrails and regularly conduct red teaming.
- Users should comply with usage policies and attend required training.
Outside the organisation, organisations should:
- define obligations in contracts with third parties based on risk tolerance, leveraging clauses on security arrangements, performance guarantees, data protection and confidentiality;
- maintain security and control of AI agents, e.g. through scoped API keys, per-agent identity tokens and robust observability of tool calls and access history; and
- provide clear information to users on organisational accountability and user responsibilities.
Design for meaningful human oversight
Organisations should implement a system for effective oversight, involving:
- defining significant checkpoints or action boundaries for human approvals, especially for high-stakes or irreversible actions;
- designing approval requests to be contextual and digestible;
- training humans to identify common issues with agent outputs;
- regularly auditing the effectiveness of human oversight; and
- complementing human oversight with real time monitoring and alert tools.
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3. Implement technical controls and processes
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Apply technical controls during design and development
Technical controls should be implemented to mitigate identified risks. Organisations are encouraged to refer to sample controls in the Cyber Security Agency of Singapore’s Draft Addendum on Securing Agentic AI and the Government Technology Agency of Singapore’s Agentic Risk and Capability Framework.
Test agents before deployment
Organisations should continue to adopt best practices on software and LLM testing, and address agentic AI-specific concerns through testing that covers:
- new risks in overall task execution, policy compliance, tool calling and error response;
- agent workflows;
- multi-agent system collaboration;
- performance in real or realistic environments;
- repeated rounds of testing across varied datasets; and
- the use of multiple evaluation methods.
Continuously monitor and test agents during deployment
Agents may be deployed on a gradual basis to reduce risk exposure. Post-deployment, reporting and failsafe mechanisms should be implemented to allow organisations to:
- stop agent workflow and escalate to a human supervisor upon failure detection;
- identify points of failure in an agent’s workflow and interaction with other agents; and
- regularly audit the system for effectiveness.
When setting up a monitoring system, organisations should consider monitoring objectives, alert thresholds and intervention protocols.
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4. Enable end-user responsibility
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Focus on transparency for users who interact with agents
Users who interact with agents on behalf of the organisation (e.g. customer service or sales agents) should be informed of:
- user responsibilities, e.g. verifying information;
- the fact that they are interacting with agents;
- agents’ range of actions and decisions;
- how the agent collects, stores and uses data; and
- human contact points for escalation.
Focus on education for users who integrate agents into their work process
Users who use agents as part of their workflow should be trained on:
- foundational knowledge on agents, including use cases, prompting best practices, agents’ range of actions; and
- effective oversight of agents, including common issues with output.
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What’s Next?
Being the first-of-its-kind, the MGF provides valuable practical guidance for the effective governance of agentic AI. Organisations deploying agentic AI or planning to adopt agentic AI solutions should evaluate their use cases against each dimension of the MGF to ensure responsible implementation and risk mitigation.
The IMDA has also emphasised that the MGF is a living document and is inviting suggestions for refinement. Organisations may submit their agentic AI governance experiences for practical use case studies on the implementation of the MGF. Feedback will be implemented into an updated version of the MGF and contributors will be recognised.
Against the backdrop of Singapore’s evolving AI governance landscape, organisations should take proactive steps to future proof their AI practices. Such steps include mapping existing and planned AI use cases against the various frameworks issued by IMDA, Personal Data Protection Commission Singapore or Monetary Authority of Singapore as may be applicable and reviewing internal policies and controls for alignment with emerging expectations.
Developing an organisation-wide AI governance approach is also vital in ensuring consistency across different AI systems, including agentic, generative and traditional AI.
If you would like tailored advice on aligning your organisation’s adoption of AI with any of Singapore’s governance frameworks or broader policies on AI, please contact us for further information.