How Europe’s Boards Are Overseeing and Disclosing on AI in 2026

Across Continental Europe,¹ defined board oversight of artificial intelligence is less established than in North American markets, but is catching up quickly.² Fiscal year 2025 had marked the emergence of AI governance as an area of board oversight, with 21% of large-cap European companies having defined AI policies in place, and a further 18% referencing AI risks or oversight in annual reports (Figure 1).³ Over the following year, it appears that companies have expanded their disclosure around the governance of AI technologies significantly.   

Having AI Policies and Oversight at Large-Cap Companies

In 2026, approximately 54% of European large-cap companies had defined AI policies in place, and a further 22% referenced AI oversight in their disclosures. The proportion of companies with no disclosure on AI oversight fell from 61% in 2025, to approximately 24%, as shown in Figure 1 below. 

Figure 1. AI Policies and Oversight at Large-Cap European Companies, 2025-2026

_{Source: Glass Lewis Research.}

Additionally, the adoption of AI policies increased from 2025 to 2026 in every region in Europe. Iberian large-cap companies reported the highest prevalence, with around 64% of Spanish companies disclosing an AI policy, followed by France at 57% and the DACH region at 56%. In the Nordic markets, where adoption of AI policies lagged compared to other regions in 2025, the proportion of companies with defined AI policies went from around 9% to 50% in 2026. 

Figure 2. Prevalence of AI Policies Across Select European Markets, 2025 - 2026

_{Source: Glass Lewis Research.}

Of companies with board-level AI oversight in place, 29% stated that the entire board retained accountability for AI-related matters, while around 24% identified either the audit committee or the risk committee as responsible.  

Adoption and Disclosure Rates by Sector

The rate of adoption of AI policies has varied by sector, although the disclosure of defined AI policies has increased across all sectors during the past year. Communication services, information technology and health care continue to rank as the three sectors with the highest adoption rates in 2026 (Figure 3).   

Figure 3. AI Policy Adoption by Sector at Large-Cap European Companies, 2025 - 2026

_{Source: Glass Lewis Research.}

Reporting on AI Governance 

Among large-cap companies with a defined AI policy, 98% disclosed AI use cases and 93% disclosed a risk assessment around AI. However, only around 21% disclosed AI-related trainings. The latter may come as a surprise given that the EU AI Act, in effect since February 2025, requires providers and deployers of AI systems to take measures on the AI literacy of their staff, as well as of third parties operating AI systems on their behalf.⁴ Among large-cap companies with a defined AI policy, approximately 56% referenced the EU AI Act explicitly.  

Despite the deferral of certain obligations (of which more below), disclosure around AI governance has clearly made progress in the past year, suggesting that companies in Europe are responding to stakeholder expectations, as well as regulatory deadlines. The relatively low levels of transparency around board and committee accountability in charters and AI-related training are likely to be the next areas of enhanced disclosure.  

Disclosing on AI Despite Regulatory Uncertainty

European large-cap companies prepared their yearly disclosures in the context of regulatory uncertainty. On November 19, 2025, the European Commission proposed deferring requirements for high-risk AI systems from August 2, 2026.⁵ The Digital Omnibus on AI entered into force on July 27, 2026,⁶ deferring obligations for standalone high-risk AI systems, such as those used in recruitment, employee management and creditworthiness assessment, to December 2, 2027, and for AI utilized in regulated products, such as machinery and medical devices to August 2, 2028. Requirements around transparency regarding where individuals interact with AI systems were not deferred and applied from August 2, 2026.  

On a regional level, regulatory rules and guidance on AI is still evolving across the continent. While bodies such as the German Corporate Governance Commission provide guidance on AI oversight by supervisory boards, and the Dutch Corporate Governance Code references responsible AI use in its explanatory notes, explicit recommendations around AI have been limited in national corporate governance codes. However, that could be changing. 

Spain established the EU’s first dedicated national AI supervisory authority (the AESIA) in 2023, ahead of the EU AI Act’s entry into force.⁷ With many Spanish issuers having already adopted AI policies,⁸ local regulators are taking steps to integrate AI oversight: in late 2025, the Spanish Securities Commission (CNMV) announced that it had begun renewing the Spanish Good Governance Code of Listed Companies, with AI and cybersecurity among the announced themes. If the updated code introduces recommendations around AI, Spain could become one of the first EU member states to embed AI oversight expectations directly within its corporate governance code, perhaps helping to close the distance on AI between Europe and its North American peers.

On October 13, 2026, Glass Lewis’ Europe and UK Research team will hold a webinar reflecting on the key governance, voting and market developments that shaped the 2026 proxy season, and highlight insights from our Proxy Season Review reports. Sign up to participate.