United States - North Carolina - AI Governance (24)

Overview

North Carolina Executive Order No. 24, titled “Advancing Trustworthy Artificial Intelligence That Benefits All North Carolinians,” was signed by Governor Josh Stein on September 2, 2025. This Executive Order establishes a robust governance structure aimed at ensuring the responsible, ethical, and effective deployment of artificial intelligence (AI) across North Carolina's state government and throughout its economy. Recognizing AI as a transformative technology with both extraordinary opportunities and inherent risks, the Order emphasizes the State's commitment to leveraging AI to enhance government operations, drive economic growth, and improve the lives of all North Carolinians. It mandates the creation of the North Carolina AI Leadership Council, the North Carolina AI Accelerator within the Department of Information Technology (NCDIT), and individual AI Oversight Teams within each Cabinet agency. The Executive Order became effective immediately upon signing and is set to remain in effect until December 31, 2028, unless rescinded or extended, with specific provisions for the continued operation of the AI Accelerator beyond this sunset date for the Council (NC Governor).

The overarching goal of Executive Order No. 24 is to position North Carolina as a national leader in AI literacy, governance, and deployment. It seeks to balance the promotion of AI-driven innovation and economic development with the critical need to safeguard civil rights, privacy, and security. The order builds upon previous state efforts, such as the North Carolina Department of Information Technology’s (NCDIT) August 2024 publication of the North Carolina State Government AI Responsible Use Framework, demonstrating a continuous commitment to thoughtful AI integration (NC Governor).

Definitions

Executive Order No. 24 itself does not provide a comprehensive list of definitions for key AI-related terms such as 'artificial intelligence,' 'generative AI,' 'deepfake,' or 'synthetic media.' Instead, a crucial duty assigned to the North Carolina AI Accelerator, established by this Order, is the “identification and standardization of state-wide definitions for AI and Generative AI” (NC Governor). This approach acknowledges the rapidly evolving nature of AI terminology and ensures that North Carolina’s understanding and application of these terms can adapt over time. By tasking the Accelerator with this responsibility, the Order sets the foundation for consistent and clear communication and policy development regarding AI across all state agencies and stakeholders.

Governance and Institutional Framework

Executive Order No. 24 establishes a multi-layered governance and institutional framework for AI in North Carolina, comprising three primary entities:

• North Carolina AI Leadership Council: This Council is established to advise and support the Governor and state agencies on AI strategy, policy, and training, with the ultimate goal of making North Carolina a national leader in AI literacy, governance, and deployment. The Council is co-chaired by the Secretary of the North Carolina Department of Information Technology and the Secretary of the North Carolina Department of Commerce. Its membership is diverse, consisting of up to twenty-five members appointed by the Governor, representing government, academia, and the private sector. Members serve two-year terms and may be reappointed. The Council's duties include creating a recommended State AI Strategic Roadmap, recommending additional AI policy and ethics frameworks, developing an AI literacy strategy, providing guidance on public safety and critical infrastructure protection from AI risks, tracking labor market impacts, and offering recommendations to other state departments regarding workforce and economic development. The Council is also tasked with providing input to the North Carolina Energy Policy Task Force concerning the energy and water consumption impacts of AI. NCDIT provides administrative support for the Council (NC Governor).
• North Carolina AI Accelerator: Established within the North Carolina Department of Information Technology (NCDIT), the Accelerator serves as the State's centralized hub for AI governance, research, partnership, development, implementation, and training. Its primary duty is to promote trustworthy AI use, transparency, data privacy, and responsible AI development through strategic oversight of state AI efforts. Key functions of the Accelerator include identifying and standardizing state-wide definitions for AI and Generative AI, developing an AI Governance Framework (encompassing principles of fairness, accountability, transparency, security, privacy, and civil liberties), and creating a risk-assessment framework for AI use cases. The Accelerator is also responsible for leading the development and implementation of AI literacy training programs for state employees and the public, aligning with the strategic direction provided by the AI Leadership Council. The Accelerator is led and staffed by NCDIT (NC Governor).
• Agency AI Oversight Teams: Each Cabinet agency is required to establish an Agency AI Oversight Team to lead AI-related efforts within their respective agency. These teams must consist of a minimum of four members and, to the extent practicable, collectively possess a mix of business, policy, and technical expertise, including artificial intelligence, data management, privacy, and cybersecurity. These teams are crucial for the practical implementation and oversight of AI initiatives at the agency level (NC Governor).

Key Focus Areas

• AI Governance Framework Development: The AI Accelerator is tasked with developing an AI Governance Framework. This framework will outline essential principles for responsible AI use, including fairness, accountability, transparency, security, privacy, and the protection of civil liberties, ensuring consistent trustworthy AI use across state government (NC Governor).
• Risk Assessment Framework for AI Use Cases: The Accelerator will also develop a risk-assessment framework. State agencies are mandated to use this framework when submitting AI use case proposals, ensuring a standardized approach to evaluating potential risks associated with AI deployment (NC Governor).
• State AI Strategic Roadmap: The AI Leadership Council is responsible for creating a recommended State AI Strategic Roadmap. This roadmap will ensure alignment with statewide objectives and adapt to emerging AI trends, guiding North Carolina's long-term AI strategy (NC Governor).
• AI Policy, Governance, and Ethics Frameworks: The Council will recommend additional frameworks that promote safety, transparency, fairness, and privacy in AI development and deployment. These recommendations will ensure that AI use adheres to high ethical standards (NC Governor).
• AI Literacy Strategy and Training: The Order mandates the development of an AI literacy strategy for the state to enhance public understanding, skill development, and effective utilization of AI. The AI Accelerator will coordinate with various state stakeholders to develop and disseminate AI literacy trainings, accessible to the general public, covering foundational AI concepts, identifying AI-related fraud and misinformation, ethical considerations, and safety (NC Governor).
• Workforce Development and Economic Impact: The AI Leadership Council is tasked with tracking current and projected labor market impacts due to AI and providing guidance to workforce development partners. It will also provide AI workforce recommendations to the Department of Commerce and the Governor’s Council on Workforce and Apprenticeships to incorporate AI topics and goals into their strategic plans (NC Governor).
• Public Safety and Critical Infrastructure Protection: The Council will provide guidance on safeguarding public safety and critical infrastructure from AI-related risks. This includes developing risk management strategies and protocols to prevent misuse or failure in high-impact AI systems (NC Governor).
• Energy and Water Consumption Impacts: Recognizing the significant demands AI infrastructure can place on resources, the Council will provide input to the North Carolina Energy Policy Task Force. This input will help assess the energy and water consumption and environmental impacts of increased AI technology use and potential added AI infrastructure in the state (NC Governor).
• Improving Government Operations: The Executive Order highlights the deployment of AI by the State of North Carolina to improve government operations. This includes identifying unnecessary or overly burdensome regulations and providing user-friendly AI agents to help North Carolinians navigate state services more efficiently (NC Governor).

Implementation Framework

The implementation of Executive Order No. 24 is structured around the immediate establishment and ongoing work of the AI Leadership Council, the AI Accelerator, and the Agency AI Oversight Teams. The Executive Order became effective immediately upon its signing on September 2, 2025 (NC Governor). The AI Leadership Council has an initial set of deliverables due by June 30, 2026, and an ongoing responsibility to advise, update, and support thereafter. This phased approach allows for foundational work to be completed while maintaining flexibility for continuous adaptation to the evolving AI landscape. The Accelerator is tasked with ongoing duties such as developing statewide definitions, governance frameworks, and risk assessment tools. Each Cabinet agency's AI Oversight Team is responsible for leading AI-related efforts within its specific domain, ensuring that the principles and frameworks developed centrally are integrated and applied effectively at the operational level. State agencies that are not members of the Governor's Cabinet are encouraged to provide use cases to the Accelerator for piloting (NC Governor).

Monitoring and Evaluation

Monitoring and evaluation are integral to Executive Order No. 24's framework. The AI Leadership Council has an ongoing responsibility to advise, update, and support the Governor and state agencies on AI strategy, policy, and training. This implicitly includes monitoring the progress of AI initiatives and the effectiveness of implemented policies. The Council is explicitly tasked with determining what information about high-risk AI use cases is important to provide to the public, implying a commitment to transparency in reporting on AI deployment and its impacts. Furthermore, the AI Accelerator's duties include reporting and accountability measures, ensuring that AI governance and implementation efforts are regularly reviewed and refined based on input from the Council. The Agency AI Oversight Teams, by leading AI efforts within their respective agencies, will also be instrumental in continuous monitoring of AI system performance and compliance with established frameworks (NC Governor).

Penalties, Liability, and Appeals

Executive Order No. 24 primarily focuses on establishing governance structures, principles, and frameworks for the responsible use of AI within North Carolina state government. The Order itself does not specify criminal penalties, civil penalties, fines, or an appeals process for non-compliance. Instead, it directs the AI Accelerator to develop an AI Governance Framework outlining principles for responsible AI use and a risk-assessment framework for AI use cases (NC Governor). It is expected that any future policies, regulations, or legislation developed under the guidance of these frameworks may address issues of penalties, liability, and redress mechanisms. However, the Executive Order itself does not create a private cause of action or specify enforcement mechanisms beyond the directive for agencies to comply with the established governance structures and frameworks.

Relationship to Other Instruments

Executive Order No. 24 is issued under the authority vested in the Governor pursuant to N.C. Gen. Stat. 147-12, which grants the Governor the authority and duty to supervise the official conduct of all executive and ministerial officers (NC Governor). This demonstrates the Executive Order's grounding in existing state law. The Order also explicitly acknowledges and builds upon previous state efforts, noting that in August 2024, the North Carolina Department of Information Technology (NCDIT) published the North Carolina State Government AI Responsible Use Framework. This indicates that Executive Order No. 24 is intended to complement and expand upon existing state guidelines for AI, providing a more comprehensive and institutionalized approach to AI governance. While the Executive Order sets out a framework for state agencies, it does not directly supersede other federal or state laws related to technology, data protection, or civil liberties; rather, it seeks to ensure that AI deployment within North Carolina adheres to and upholds such existing legal and constitutional protections. The frameworks and policies to be developed under this Order are expected to align with, and where appropriate, integrate with, broader legal and ethical standards.

International Alignment

As an executive order issued at the state level within the United States, North Carolina Executive Order No. 24 primarily focuses on domestic AI governance and policy within the state's jurisdiction. Therefore, its direct alignment with international standards or other jurisdictions' AI regulations is not an explicit stated objective within the document. However, the principles outlined for responsible AI use, such as fairness, accountability, transparency, security, privacy, and the protection of civil liberties, are broadly consistent with ethical AI principles and regulatory approaches being discussed and adopted by international bodies and other leading jurisdictions globally. While not explicitly referencing international treaties or foreign laws, the foundational ethical considerations embedded in the order reflect a general global consensus on the responsible development and deployment of AI. The establishment of an AI Leadership Council and an AI Accelerator suggests an intent to stay abreast of best practices, which may indirectly lead to alignment with evolving international norms in AI governance (NC Governor).

Implementation Timeline

Compliance Checklist

Sources and References