Image Attribution: Yutong Liu / https://betterimagesofai.org / https://creativecommons.org/licenses/by/4.0/

January 2025 saw IndiaAI release a report on AI Governance guidelines and invite comments till February 2025. Aapti Institute had prepared and submitted comments based on discussions within the organization and our work on artificial intelligence and other relevant topics.

Aapti’s submission offered thematic commentary as well as more specific comments. The thematic commentary mainly covered three topics: AI labour, natural resources and environmental risks, and the operationalizing of AI governance principles. The AI industry relies on a growing workforce of data workers for roles like providing training data to develop capabilities. Data work is sourced through a variety of business models, and lacks data that can help us understand the Indian landscape. We need data and policy measures for this important industry.

As the AI sector expands and spreads, the technology and products’ environmental impacts must be considered seriously. Indian understandings of AI governance must consider the material and sustainability aspects of the AI lifecycle. Decarbonisation and reducing the water footprint of components like data centres are key pathways to pursue.

In addition to enhanced attention towards the labour and environmental aspects of the AI sector, fairness, transparency, and talent are some areas to consider. Understanding AI bias across contexts and groups, accessible databases documenting AI incidents, and wide information-sharing with international allies are some noteworthy pathways.

Our specific comments include seeking the inclusion of data workers as stakeholders and focus areas, adding labour-related commitments, and expanding the membership of the non-official members to feature civil society organisations and academia.

AI governance is an essential subject in the wider discussions and interventions regarding the AI sector, and lifecycle approaches will benefit from including topics like labour and environment in their focus. Aapti Institute’s submission is included below.

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