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Rita Bateson7 min read
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3 things schools still aren’t really thinking about – but should be
by Rita Bateson(Co-Founder, Eblana Learning) 30 May 2026 9 min read
Last week, I found myself in a room full of lawyers, regulators and civil servants at William Frye’s annual AI summit – and not many people mentioned education. And yet, I still felt oddly at home.
Why? Because everything they discussed – high‑risk AI, sectoral regulation, forbearance around children, operational resilience – lands squarely in our world too. If businesses need to act now because of the EU AI Act, then so do schools.
1. Putting “doing the right thing” first, not last
Let’s start where, in my view, everyone should start: ethics before enforcement.
The EU AI Act gives us a legal and regulatory frame, but schools cannot outsource their moral compass. We need:
Let’s start where, in my view, everyone should start: ethics before enforcement.
2. Identifying where “high‑risk AI” actually lives in your school
The summit conversation around “high‑risk” AI was framed for business, but the translation for schools is straightforward and urgent:
The EU AI Act pushes organisations to map and mitigate high‑risk uses. Schools should be doing the same: inventory first, response second. You cannot manage what you cannot see.
3. Naming people who are responsible for AI, regulation, and governance
One of the strongest messages from the summit was the need for dedicated people*who wake up thinking about AI governance.
In schools, that means moving towards:
If everyone is responsible, often no one is. The EU AI Act environment rewards institutions that can show their homework. Schools must be able to say: “These are our people. This is our process.”
Businesses at the summit talked about expanding their “playbooks”. Schools need the same, but with education‑specific scenarios, such as:
A playbook answers:
5. Getting legal advice before you’re uncomfortable
One of the clearest takeaways: don’t wait until you’re in trouble to talk to a lawyer.
Schools sign contracts with AI‑enabled edtech providers all the time. The EU AI Act sits on top of existing GDPR and sectoral legislation – it does not replace them. If you’re:
…that’s a signal to **get legal eyes on the situation now**, not after a complaint, breach, or press story.
Legal advice can be part of designing better partnerships with providers who also want to get this right.
6. Understanding that the EU AI Act is an add‑on, not a parallel universe
Another powerful thread at the summit: the EU AI Act is an extension of an existing orbit. For schools this means:
So rather than asking, “What is our AI policy?” in isolation, ask:
AI simply turns up the volume on your current obligations.
7. Looking across the whole system – Eblana’s “6Ps” lens
At the summit, there was a constant reminder that AI has implications across multiple dimensions. In Eblana Learning we often talk about the 6Ps as a practical lens for schools: People, process, preparation, protections, policies and pedagogy.
The EU AI Act is an invitation to look at how AI touches every part of school life – from timetable construction and behaviour logs to creative projects and pastoral care.
8. Committing to ongoing monitoring and impact assessment
A phrase that echoed through the summit was the need for continuous assessment, not one‑off audits.
For schools, this could mean:
We are good, in education, at “pilot and forget”: we try something, announce success, then move on. AI demands a different posture: **check, learn, adjust, repeat**.
9. Getting crystal clear on AI governance and policies
Every school needs clarity on:
Clear, accessible policies also build trust with parents who are increasingly asking, “What is my child’s school doing with AI?” You should be able to answer that confidently, not reluctantly.
10. Building operational resilience – keeping the work going
Finally, schools need to think seriously about operational resilience:
At the summit, cooperation and collaboration were framed as hard, necessary work. The same is true in schools: **responsible AI doesn’t run on enthusiasm alone**. It needs structures, partnerships, and time.
Alongside these ten, there were three big ideas that, in my experience, are still under‑discussed in schools.
1. Forbearance in emotionally sensitive domains
The term forbearance came up in relation to toys and AI around children – essentially, regulators choosing to hold back, to move cautiously where emotional and developmental risk is high.
Education is *full* of emotionally sensitive domains:
Forbearance is a powerful concept for schools: sometimes the ethical move is to not automate, not predict, not quantify.
2. The slide from edtech to ad‑tech
At one point I misheard “ad tech” as “edtech” – and then realised how painfully close the two can be.
Our concerns about edtech are not just about screen time or distraction; they are increasingly about commodification of student data:
The EU AI Act takes a stance on certain manipulative and exploitative uses of AI. Schools need to examine whether their tools, contracts, and data flows are edging towards **ad‑tech logic** under an edtech badge.
Dependency is one issue. Lifetime access to our students as consumers is another level of concern entirely.
3. Ex ante arrangements – acting before harm is visible
Translated into school practice, this might look like:
We are very used to post‑hoc conversations in education – we notice a problem, then patch around it. Ex ante thinking asks: *How do we design so that the most serious harms are unlikely to arise in the first place?*
Despite language like “threat level penetration assistance” (which frankly sends me to a dark place when I think about its implications for children and learning), I left the summit more hopeful than I expected.
Why?
Because I saw thoughtful, serious people doing serious work to protect not just markets but also fundamental protections around cognition, creativity and democratic life.
Our task in education is to:
If the EU AI Act is prompting businesses to get their house in order, we should seize this moment to do the same in schools – out of a deep commitment to doing the right thing, visibly, and together.
At a glance
This article argues that the EU AI Act should prompt schools to examine how they use AI across governance, safeguarding, data protection, and teaching. It outlines ten priorities for schools, including ethics-first decision-making, identifying high-risk uses, assigning responsibility, planning for incidents, and monitoring impact over time.
Useful for: School leaders, Governors and boards, Safeguarding teams, Data protection and privacy leads, Teachers and school staff involved in AI use, Education policy and edtech decision-makers
Schools should respond to the EU AI Act by strengthening AI governance, ethics, and accountability across the whole school, rather than treating AI as a separate technical issue.
It highlights AI in assessment, admissions, behaviour analytics, safeguarding, wellbeing monitoring, special educational needs, and any tool that profiles, predicts, or ranks students.
It argues that schools need specific people or teams responsible for AI policy, practice, and risk so that governance is clear and actionable.
It says the EU AI Act adds to, rather than replaces, existing obligations such as GDPR, safeguarding duties, child protection frameworks, and vendor oversight.
It means acting before harm happens by using impact assessments, setting red lines, and agreeing expectations with vendors in advance.
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Could there be such a thing as a Swiss polaroid model?
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