UN AI Governance Submission

On 22 April 2026, Felaris Global LLC submitted a written contribution to the first United Nations Global Dialogue on Artificial Intelligence Governance. The Dialogue was established by the UN General Assembly under the Global Digital Compact. Its first session convenes in Geneva on 6 and 7 July 2026, co-chaired by the Permanent Representatives of El Salvador and Estonia and supported by a joint secretariat of UNESCO, ITU, the Executive Office of the Secretary-General, and the UN Office for Digital and Emerging Technologies.

The Felaris submission, Governing AI in Regulated Mid-Market Companies: An Operator's Perspective, argues that the AI governance frameworks currently being drafted at the UN, OECD, EU, and national sector-regulator level assume enterprise-scale organizational infrastructure that most regulated companies do not have. It offers four operator-level recommendations to the Co-Chairs.

Mid-market regulated companies, with annual revenues between fifty million and five hundred million United States dollars, carry material compliance obligations under FDA, EMA, EU MDR, SOX, and the newer AI instruments. They also carry limited governance infrastructure. Nominal adoption of a framework is not the same as substantive implementation. Operations in smaller jurisdictions, including the English-speaking Caribbean, compound the gap.

The paper recommends four things to the Co-Chairs. First, that the Dialogue address mid-market implementation explicitly in its first-session thematic structure and in the Co-Chairs' summary. Second, that new AI governance instruments be required to interoperate with the sector frameworks regulated industries have spent two decades building, including 21 CFR Part 11, EU Annex 11, IEC 62304, SOX, and ISO/IEC 42001 and 27001. Third, that mid-market regulated industry operator voices be included deliberately in future thematic discussions, alongside enterprise and Big Tech participants. Fourth, that organisational capacity-building in smaller jurisdictions be treated as a distinct workstream alongside sovereign capacity-building.

For a $200M PE-backed medical device, pharmaceutical, or finance company, the question is no longer whether to adopt AI governance. Auditors, notified bodies, customers, and investors are already asking. The question is whether the posture documents that get written actually survive an inspection. The submission addresses that question directly.

For operators in the English-speaking Caribbean, Felaris's submission puts the dependency of smaller jurisdictions on multilateral reference material on the UN public record, with Trinidad and Tobago, Jamaica, and other CARICOM member states named specifically. Regional government entities are engaging on how that material should inform local positioning.

For US and European clients, the paper anchors Felaris in validated-industry discipline and positions the firm at the policy level as well as at the project level.

The full written submission is available on request. Email klaus.feldam@felarisglobal.com to receive the PDF.