AI Compliance: Where to Start?
UPDATED May 28, 2026
The Law in Plain Language
On April 13, 2026, HB 1186 and SB 394 were signed into law, formally designated as Chapters 937 and 943 of the 2026 Virginia Acts of Assembly and codified as § 22.1-20.2:1 of the Code of Virginia. The effective date is July 1, 2026. This summary analysis covers the law’s scope, definitions, requirements, and open-ended policy questions. This informal summary analysis can also be a quick read before your division starts building policy, reviewing contracts, or evaluating AI tools for compliance.
Explore the New Requirements →
The Starting Point
Virginia Code Section 22.1-20.2:1 requires every Virginia school division to operate a Division-Managed AIS Platform, establishing, implementing, and enforcing policies governing the use of AI in instructional settings. The law is in effect July 1, 2026. VDOE policy guidance is expected to follow, and divisions that have already done the foundational inventory work will be in a significantly better position to build policy quickly when that guidance arrives. Most divisions are still operating without a clear structure for how to respond. This page can be a starting point.
1. Before the Policy: Two Questions Every Virginia Superintendent Should Be Able to Answer.
Start here if you need to understand your division’s current position.
These two questions are designed for superintendents and leadership teams. They establish whether your division has a clear picture of which AI tools are active in your environment and whether your existing vendor agreements actually cover that use. When VDOE guidance publishes, divisions that have already answered these questions will move faster and with less disruption.
2. Before the Policy: Question 3 ~ What Is your staff Already Using?
Start here after completing the Two Questions to understand what your staff is already doing on their own.
This survey is designed for superintendents and IT staff to complete a simple anonymous inventory of AI tools already in use inside the building. No technology required, no budget needed, and no one gets in trouble. Just information your division needs before policy decisions have to be made.
Explore the Inventory Survey →
A Readiness Review provides a map of a division’s current AI inventory, documentation status and compliance issues.
3. Data Readiness
Why the data behind your systems matters as much as the systems themselves.
Before you can use data well, you have to know what you have. Most divisions are sitting on years of accumulated records in formats that were never designed to work with AI systems. Before any deployment decisions are made in the future, the data readiness question has to be answered. The divisions that address this sooner rather than later will be significantly better prepared when that day comes.
4. Sovereign AI: Privacy-First Local AI (PFLA)
The next step for divisions wondering about the future direction of Division-Managed AIS
Section 4 is for divisions thinking beyond immediate compliance.
This analysis is provided for informational purposes only by Strategic AI Link (SAIL), an independent AI compliance consultancy based in Virginia Beach, Virginia. It does not constitute legal advice. School divisions should consult legal counsel for division-specific compliance decisions. · This is a living document. Content reflects current understanding and is subject to update as the field evolves. · Strategic AI Education LLC · June 2026