Governance framework & guidance

What is a Material Change?

A Material Change is a change significant enough that the organisation should reconsider some part of the existing governance position. It does not need to be harmful; it simply needs to matter to a conclusion that was previously assessed, controlled or approved.

Examples include changed purpose, people affected, decision influence, human oversight, information, automation, scale, Product capabilities, supplier arrangements or Controls.

Not every update is material

AI Products can change frequently. The useful question is whether the change alters something material to the way the organisation assessed, controlled or approved the AI Use. Routine interface updates should not create unnecessary reassessment, while new autonomous capabilities might.

Preventing governance drift

Governance drift occurs when actual use gradually diverges from what was originally assessed and approved. Small changes in purpose, reliance, automation or information can accumulate until the live AI Use bears little resemblance to the governed record.

Material Change management helps keep the system connected to reality.

Report facts, not governance conclusions

A contributor should be able to say “the way we are using this has changed and I’m not sure whether it matters”. The governance process can determine the consequence.

This follows the same Swell principle used throughout the product: ask contributors for observable facts and route specialist judgement to appropriate people and deterministic rules.

Using Swell AI

What can happen after a Material Change?

  • No further governance change required.
  • Action required.
  • Control review required.
  • Risk reconsideration required.
  • Reassessment required.
  • Reapproval required.

Reassessment creates a new Assessment cycle

When reassessment is required, Swell creates a new Assessment cycle and preserves the previous one as historical evidence. Current facts can be reused where they remain valid so users are not forced to repeat unnecessary questions.

The same principle applies to reapproval: a new authorised decision can be recorded without erasing the original decision.