AIS Innovation in Education Pilot Program
UPDATED April 29, 2026
HB 1186 / SB 394 – Full Compliance Analysis for Virginia’s Division-Managed AIS Platform is now formally designated as Chapter 937 of the 2026 Virginia Acts of Assembly. SB 394 is now formally designated as Chapter 943 of the 2026 Virginia Acts of Assembly. These bills are no longer pending legislation, they are enacted Virginia law, codified as § 22.1-20.2:1 of the Code of Virginia. The foundational reference for what the law actually requires.
On April 13, 2026, Governor Spanberger signed Chapters 937 and 943 into law. The effective date is July 1, 2026. This analysis goes through the enacted text section by section – every definition that carries legal weight, every obligation placed on school boards, every requirement the law sets for vendor agreements and monitoring systems, and every gap the legislation creates but leaves unanswered. It is the document to read before your division starts building policy, reviewing contracts, or evaluating AI tools for compliance.
Explore the New Requirements →
AI Compliance: Where to Start?
Think of it this way. School systems have two kinds of libraries. The Main Campus Library – vast, powerful, open to everyone – is the cloud. Google, Microsoft, the big platforms. Your data travels there to be processed. The Satellite Local Library is your division’s local on site AI. Small, focused, protected, and it serves only you. Personal and identifiable data stays there. Contained. Yours. In this model, Division-Managed AI Systems (AIS) work exactly the same way.
Virginia’s AI compliance requirements are evolving quickly. 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 ~ Staff, Teachers and Students: What Is Everyone 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 →
3. Before the Policy: 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 decision is made, the data question has to be answered. The divisions that address this now will move significantly faster than the ones that discover the problem after the system is already in place.
4. Sovereign AI: Privacy-First Local AI (PFLA)
The next step for divisions thinking beyond immediate compliance.
PFLA outlines a model where AI processing and data control remain local to the division. It addresses the underlying issue HB 1186 points toward – not just policy compliance, but actual institutional control over student data, systems, and outcomes.
How to Use This Page:
Follow the first 2 steps to establish where your division stands today. Step 3 introduces the concept of Data Readiness. This is a critical component to a well formed AI action plan. Step 4 reviews PFLA to understand the longer arc of the local AI systems evolving into the Hybrid model where AI governance in public education is heading.
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 · April 2026