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Good practice

Denmark's Dual-Layer AI Governance Framework for Schools

Denmark · Copenhagen · See the Denmark profile

Denmark's Ministry of Education issued seven AI-in-schools recommendations in June 2025, complemented by Datatilsynet's 2023 GDPR guidance, forming a dual-layer framework covering lawful processing, data minimisation, and teacher competency for responsible AI integration.

Details

Maturity
Scaling
Promoter
Styrelsen for Undervisning og Kvalitet / Datatilsynet
Period
2023-2026
Keywords
education, data protection, ai governance, government

Context

Denmark's governance of AI in schools rests on a dual-layer framework built between 2023 and 2026. The regulatory foundation was laid in October 2023 when Datatilsynet (the Danish Data Protection Authority) published guidance applicable to all public institutions including schools, requiring a lawful legal basis for AI deployment, data-protection impact assessments, data minimisation and purpose-limitation, and transparency towards students, parents and staff.

Objectives

The pedagogical layer arrived in June 2025, when the Ministry of Children and Education's Styrelsen for Undervisning og Kvalitet published seven recommendations for primary schools on generative AI in instruction: establish unified AI frameworks, ensure GDPR compliance, facilitate staff dialogue, strengthen teacher pedagogical competencies, deploy AI only when educationally justified, engage students in critical reflection, and keep parents informed.

Activities

In January 2026 the ministry supplemented both layers with an 'AI mini-guide' for all educational institutions, including vocational colleges, giving concrete examples of lawful AI use, copyright clarification for AI-generated content, and guidance on institutional responsibility for vetting digital tools.

Conclusions

The European Commission's Eurydice network and CEDEFOP have both cited Denmark as a model for multi-layer, data-protection-first AI governance in education, but individual schools retain responsibility for implementation and no national student learning-outcome evaluation has been published to date.

Implementation

Indicative cost
Medium (€50k–€500k) — Regulatory guidance and mini-guide production; enforcement uses Datatilsynet's existing authority.
Time to results
Medium (1–3 years) — Built in layers over three years: Datatilsynet guidance (Oct 2023), ministry recommendations (June 2025), AI mini-guide (Jan 2026).
Staffing & skills
Datatilsynet (Danish Data Protection Authority), Styrelsen for Undervisning og Kvalitet (Ministry of Children and Education agency)

Conditions for success

  • Lawful legal basis and Data Protection Impact Assessments required before any AI deployment
  • Staff dialogue on AI's benefits and limitations
  • Parents kept informed of the school's AI approach

Common failure modes

  • Individual schools retain responsibility for implementation, so consistency across schools is not guaranteed
  • No national student learning-outcome evaluation has been published to date

Where it fits

Governance type
national data-protection authority plus ministry guidance (dual-layer)
Scale
national (all folkeskolen, secondary and vocational institutions)
Income level
high income

Data sources

Where this practice's information was retrieved from, and when.

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