When the pace of AI adoption outstrips the readiness of governance and compliance frameworks, the majority of executives (56% in EMEA) continue the rollout within agreed-upon risk limits while governance is being put in place. In Germany, as many as 64% of executives reported this. At the EMEA level, only one-third are postponing implementation entirely until governance is in place. This figure was noticeably lower among German respondents, at 23%.
The survey of more than 3,200 executives at companies in eight countries across Europe and the Middle East suggests that governance guidelines will come under increasing pressure as AI agents operate with greater autonomy. 35% of respondents are already using agent-based AI in production; among German participants, this figure is 19%. However, three-quarters expect AI agents to possess a certain degree of decision-making autonomy by 2027; German respondents, at 62%, have lower expectations in this regard. Only 37% of all respondents—38% in Germany—state that their current governance systems are designed to scale with the use of agent-based AI.
Ana Paula Assis, IBM Senior Vice President and Chair, EMEA and APAC, said: “The debate surrounding AI has shifted from adoption to governance and accountability. As companies transition from AI assistants to autonomous agents, governance can no longer be viewed solely as a compliance issue. It has become a business necessity and a driver of value creation.
The companies that can scale AI responsibly and trustworthily will reap the greatest business benefits. This means that governance must be directly integrated into the way AI agents operate—with clear boundaries on their scope of action, clearly defined responsibilities for errors, and real-time control mechanisms.”
Accountability and Liability Gap
Nearly all executives surveyed (98% in EMEA, 95% in Germany) have formally established responsibility for AI risks at the executive board level. 26% of companies in EMEA have a dedicated AI committee at the executive board level; in Germany, this figure rises to 34%. At the same time, the study shows that there is no clear consensus on who is responsible for negative consequences caused by AI agents. The most frequently cited role was CIO or CTO, but this was mentioned by only 17% of respondents, both in EMEA and in Germany.
Opinions also differ regarding legal liability in the event of significant damage caused by AI systems: 20% (in Germany: 19%) believe that liability should be shared proportionally between the user and the provider, 19% (in Germany: 22%) see the need for a regulatory framework, which is currently insufficient, and 14% (in Germany: 12%) attribute responsibility to the AI or technology provider.
To manage increasingly autonomous AI agents—which by 2027 could make decisions without human approval at every single step—executives consider the following measures to be particularly necessary:
- Formal legal or contractual provisions regarding the liability of AI providers for errors made by agents (33% in EMEA, in Germany 31%)
- Defined thresholds for escalation to humans (32% in EMEA, in Germany 29%)
- Real-time monitoring and audit trails for agents’ decisions and actions (30% in EMEA, 28% in Germany)
- The ability to immediately halt agents’ activities company-wide (29%). In Germany, only 22% of respondents considered this necessary.
Additional key findings
Measuring financial risks is less established than assigning responsibility at the executive board level: More than half of executives (54%) treat generative AI tools and agent-based AI systems as distinct risk categories with separate governance frameworks. In Germany, this applies to as many as 64% of respondents. Another 38% in EMEA use the same basic framework but supplement it with additional controls for agentic AI; in Germany, only 26% do so. The quantification of financial risks arising from governance gaps is significantly less advanced: At the EMEA level, only 37% have a formal assessment of these risks reviewed by the executive board. In Germany, 38% of participants reported this.
Supply chain risks: 54% of respondents in EMEA (in Germany: 47%) see gaps or limitations in how their governance frameworks cover AI systems and models from suppliers, technology partners, and other supply chain actors. Only 21% (in Germany: 18%) continuously monitor risks posed by third-party AI, and just 13% require independent audits or certifications. In Germany, an even smaller proportion of respondents—11%—require this.
Regulatory factors influence the pace of change differently by region: In the EU, 41% of executives are accelerating their governance investments in anticipation of the requirements of the EU AI Act for high-risk applications, which take effect in December 2027. In Germany, this figure was even higher at 50%. Another 35% in the EU are following structured compliance plans; in Germany, 22% of respondents reported doing so. In the United Kingdom, expectations from industry regulators are the most important driver for investments in AI governance (27%). In Saudi Arabia and the United Arab Emirates, requirements stemming from national AI strategies are the primary focus (61%).
Study Methodology
The study was conducted by Censuswide on behalf of IBM. The survey included 3,221 members of top management, including C-level executives, from companies with at least 1,000 employees in the United Kingdom, France, Germany, Italy, Spain, the Netherlands, Saudi Arabia, and the United Arab Emirates. Data collection took place between September 14 and 24, 2026.
About IBM
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