An Artificial Intelligence Governance Framework at Telefónica

As of 1 December 2023, Telefónica has established an Artificial Intelligence governance model, rooted in ethical principles since 2018 and reliability assessments. Highlighting business involvement, functional coordination and risk orientation, this model will be key for the company's technological advances. Telefónica sees AI as an opportunity for well-being, economic growth and positive social impact.

An Artificial Intelligence Governance Framework at Telefónica

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The opportunity for trustworthy AI

At Telefónica, we see Artificial Intelligence (AI) as an opportunity presented by technology that will result in greater well-being, significant economic boost, positive social impact and a differential element of competitiveness. For this to happen, this opportunity must be developed within a framework of trust and responsibility for its use.

Technological revolutions such as the one we are facing, generate new political, social, cultural and economic dynamics. The speed of technological change in today’s world makes it more complex to regulate, yet it makes us more aware of these ongoing transformations. At Telefónica, we are in a privileged position and at a privileged time to understand these changes. That is why we must take advantage of our knowledge, understanding and awareness of change to implement governance and risk control mechanisms, enhancing the reliability of the advantages technology offer.

A path towards AI Governance

Identifying governance mechanisms requires a process in which, alongside technology, new dynamics can be experimented with and the most appropriate solutions can be devised.

Already in 2018 we have started publishing the ethical principles of Artificial Intelligence, where we made a public commitment to uphold them.  These ethical principles prompted the generation of the first procedures and requirements for compliance with each of them.

Our active participation in the European reflection processes, such as the European Commission’s Trusted AI Assessment Checklist of the European Commission’s Expert Group helped us to lay the foundations for the identification of AI requirements.

In addition, Telefónica has had a long-standing and consolidated Privacy Governance. Founded on the implementation of a governance model based firstly on the capillarity and responsibility of the functional and business areas, secondly on risk orientation as a fundamental guide, and finally on the implementation of the corresponding mitigation measures.

In 2022 we initiated an ethical and responsible AI governance pilot, testing new roles such as a “Ethics Expert Group ” for Artificial Intelligence, “RAI Champions” and an “AI Office”, tested a methodology for evaluating products and services, and initiated training and awareness-raising on Ethical AI for the different roles. In short, during the pilot we put into pratice the necessary control mechanisms for the functioning of Artificial Intelligence Governance.

The result: Telefónica’s AI Governance Model

This entire process enabled us to internally advocate for the drafting of an internal regulation, approved on 1st December 2023. This regulation binds the Group’s companies and employees, defines the Artificial Intelligence Governance Model, and takes advantage of the best practices and lessons learned along the way:

  • Extensive reach of governance within business areas, taking responsibility for categorizing and implementing requirements for AI systems they develop, acquire, use, or market.
  • Strong coordination mechanisms at both functional and Group levels.
  • Clear risk orientation, risk identification and risk mitigation.
  • Enhanced decision-making scale by involving ethics experts where needed.
  • AI governance management rests on the Telefónica Group Compliance areas.

This Governance Model will enable Telefónica to respond both to its ethical commitments in responsible technology and to the international collaboration frameworks in which Telefónica participates, such as the one led by UNESCO or to the regulation of artificial intelligence that will be incorporated into legal systems of the different countries in which Telefónica operates.


In the coming months, we will start planning the implementation of the new regulation, which will be introduced gradually.


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