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Agent Promotion Checklist

Requirements and procedures for promoting agents between governance zones.


Overview

Agents progress through governance zones as they mature from personal experimentation to enterprise production. This checklist ensures all requirements are met before zone promotion.


Zone 1 to Zone 2 Promotion

Trigger Conditions

Promotion to Zone 2 is required when:

  • Agent will be shared with team members (beyond creator)
  • Agent accesses internal business data
  • Agent will be used for departmental workflows

Pre-Promotion Requirements

Business Requirements

  • Business justification documented
  • Manager or department head approval obtained
  • Data sources identified and approved
  • User list defined

Technical Requirements

  • Agent moved to Zone 2 environment (Managed Environment)
  • Solution created for version control
  • DLP policy compliance verified
  • Authentication configured (Entra ID required)
  • Sharing rules appropriate for Zone 2

Testing Requirements

  • Functional testing completed
  • User acceptance testing completed
  • Security review completed (if accessing sensitive data)

Documentation Requirements

  • Agent registered in inventory (Control 3.1)
  • Agent metadata complete (owner, purpose, data sources)
  • Incident response procedures documented
  • User training materials prepared

Approval Workflow

  1. Creator completes checklist
  2. Manager reviews and approves
  3. Power Platform Admin verifies technical requirements
  4. Compliance reviews (if applicable)
  5. Agent enabled in Zone 2 environment

Zone 2 to Zone 3 Promotion

Trigger Conditions

Promotion to Zone 3 is required when:

  • Agent will be customer-facing
  • Agent accesses customer PII or financial data
  • Agent makes decisions affecting customers
  • Agent used in regulatory contexts

Pre-Promotion Requirements

Business Requirements

  • Detailed business case documented
  • Executive sponsor identified
  • Risk assessment completed (Control 2.6)
  • Legal review completed (if customer-facing)
  • Regulatory alignment confirmed

Governance Requirements

  • Governance committee presentation scheduled
  • Committee review materials prepared
  • All committee member approvals obtained:
  • AI Governance Lead
  • Compliance Officer
  • CISO
  • General Counsel (if customer-facing)
  • Business Owner

Technical Requirements

  • Agent migrated to Zone 3 managed environment
  • 10-year audit retention configured
  • Phishing-resistant MFA enabled (Control 1.11)
  • Runtime protection enabled (Control 1.8)
  • DLP policies at strictest level
  • Sensitivity labels applied
  • Change management process established

Testing Requirements

  • Comprehensive functional testing completed
  • Security penetration testing completed
  • Bias and fairness testing completed (Control 2.11)
  • Performance benchmarking completed
  • Fallback scenario testing completed
  • User acceptance testing with production-like data

Compliance Requirements

  • Model risk assessment completed (Control 2.6)
  • Supervisory procedures documented (Control 2.12)
  • Disclosure requirements reviewed (Control 2.19)
  • Records retention configured (Control 1.9)

Documentation Requirements

  • Complete agent documentation package
  • Incident response playbook
  • Monitoring and alerting configured
  • Training materials for operators
  • User communication plan

Approval Workflow

  1. Business Owner completes requirements
  2. AI Governance Lead validates readiness
  3. Governance committee reviews package
  4. Committee votes on approval
  5. Post-approval implementation:
  6. Change control ticket created
  7. Phased deployment scheduled
  8. Monitoring configured
  9. Stakeholders notified

Post-Promotion Activities

Zone 2 Post-Promotion

  • Update agent inventory with new zone
  • Enable quarterly compliance reviews
  • Configure monitoring dashboards
  • Schedule first governance review

Zone 3 Post-Promotion

  • Update agent inventory with new zone
  • Enable real-time monitoring
  • Configure executive reporting
  • Schedule monthly governance reviews
  • Brief operations team
  • Conduct post-deployment review (30 days)

Promotion Denial Handling

If promotion is denied:

  1. Document specific concerns from reviewers
  2. Create remediation plan
  3. Assign remediation owner and deadline
  4. Re-submit for review when complete
  5. Track in governance records

Common Denial Reasons

Reason Typical Remediation
Incomplete testing Complete required tests
Security concerns Address findings, re-test
Documentation gaps Complete missing documentation
Unclear business case Strengthen justification
Data access concerns Implement additional controls


Last Updated: January 2026 FSI Agent Governance Framework v1.2