AI Governance and the CHRO: Aon Asset Management Roundtable
Presented at the Aon Asset Management CHRO Roundtable, May 27, 2026
Aon convened the private roundtable for Chief Human Resources Officers across leading asset management firms to examine AI's growing impact on workforce governance and HR's strategic role. The session addressed the governance gap most HR leaders are currently facing: their firms have approved AI tools, but have not approved the specific use cases those tools are being applied to — and that distinction is where both regulatory and legal liability lives.
Key Takeaways
Approving a tool and approving a use case are two different governance decisions. Most firms have an AI-approved tool list. Almost none have a use-case policy determining when AI that touches compensation, headcount, or performance decisions requires its own governance review.
The AEDT classification is not self-evident — and that's the problem. Across talent acquisition, performance management, workforce strategy, and compliance, the majority of AI applications already deployed at investment management firms qualify as Automated Employment Decision Tools under NYC Local Law 144 and similar state-level regulations — whether or not the business units using them recognize that.
Having a "human in the loop" is not a legal defense. EEOC guidance from May 2023 confirmed that employer liability for disparate impact exists regardless of who made the final call — what matters is whether a documented use-case governance review exists.
HR needs to own the inventory management, a seat at the table where decisions are made, and the language used. Lead the actual deployment inventory audit — not the approved AI list, but the list of AI tools currently touching people decisions in any fashion — and enter conversations with CIOs and CROs equipped with precise vocabulary: tool approval versus use-case approval, platform bias audit versus implementation bias test, and human in the loop versus documented human review.
