AI Governance in Biopharma Is Failing the Translation Test

Jul 2, 2026 | Regulatory

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Independent Contributor
Written by: Matt Hasan and Farah Hasan
On behalf of: aiRESULTS

Artificial intelligence is no longer experimental in biopharma. It is operational.

Across drug discovery and development, AI systems are being used to identify targets, design molecules, optimize mRNA constructs, and simulate biological interactions that were previously beyond the reach of human analysis. In immunotherapy and precision medicine, these capabilities are not just accelerating timelines. They are redefining what is scientifically and commercially possible.

But there is a growing problem that is not receiving enough attention.

Biopharma organizations have become increasingly effective at deploying AI. They have not become equally effective at governing it.

The result is a widening gap between what AI systems can do and what organizations can reliably control, explain, and defend in a regulated environment. That gap is not theoretical. It is already beginning to show up as friction in development pipelines, delays in validation, and growing tension between innovation teams and regulatory functions.

The failure is not technological. It is operational.

The Illusion of Readiness

Most large biopharma companies will tell you they are ready for responsible AI.

They have governance frameworks. They have ethical guidelines. They have compliance teams that are increasingly engaged in AI-related initiatives.

On paper, the infrastructure is there.

In practice, it is not.

AI initiatives are still largely fragmented. Data science teams operate at a different cadence than regulatory and quality functions. Governance is often layered on after models have already been developed and integrated into workflows. Oversight mechanisms exist, but they are inconsistently applied and rarely designed for the level of complexity that modern AI systems introduce.

This creates a false sense of readiness.

Organizations believe they have governance because they have documented it. But governance that cannot be executed under real-world conditions is not governance. It is intent.

Where Governance Breaks Down

The failure of AI governance in biopharma is not subtle. It shows up in predictable ways.

The first is auditability. AI-driven decisions are influencing which drug candidates move forward, how trials are designed, and how biological responses are interpreted. Yet many organizations cannot reconstruct how those decisions were made. Model versions are not consistently tracked. Training data lineage is incomplete. Intermediate decision steps are not captured in a way that can be reviewed or explained. In a regulated industry, that is a fundamental problem.

The second is human oversight. Nearly every organization claims that humans remain in the loop. In practice, that often means a scientist or reviewer signs off on an output without a clearly defined framework for validation. The criteria for accepting or rejecting AI-generated insights are rarely standardized. Oversight becomes performative rather than substantive.

The third is data governance. Bias and representativeness are widely discussed, but unevenly addressed. Datasets used to train models often reflect historical biases or lack sufficient diversity. In areas like immunotherapy, where biological responses vary significantly across populations, this is not an abstract concern. It directly affects the quality and reliability of outcomes.

The fourth is regulatory misalignment. Many organizations treat regulatory readiness as a documentation exercise. They assume that if they can explain a decision after the fact, they will satisfy regulators. But regulatory science does not work that way. Systems must be designed from the outset to support validation, traceability, and reproducibility.

Retrofitting governance onto opaque systems is not just difficult. In many cases, it is impossible.

The Real Problem: Strategy and Regulation Are Not Aligned

At the heart of these failures is a deeper issue.

Strategy and regulatory science operate on fundamentally different timelines and priorities.

Strategic teams are focused on speed. They are measured on how quickly they can move from hypothesis to candidate to clinical validation. AI is seen as a way to compress those timelines and gain competitive advantage.

Regulatory functions are focused on control. They are measured on their ability to ensure that decisions are safe, explainable, and compliant with evolving standards. Their timelines are longer by design, because the cost of error is high.

Both perspectives are valid. But in most organizations, they are not integrated.

AI initiatives are launched as strategic programs. Regulatory considerations are introduced later, often as constraints. By that point, critical design decisions have already been made.

This creates friction that slows everything down.

Projects that were supposed to accelerate development get bogged down in validation challenges. Teams scramble to reconstruct decision logic that was never captured.

The problem is not that governance is too strict.

The problem is that it is being applied too late.

What Operational Governance Actually Looks Like

 If biopharma organizations want to close this gap, they need to move beyond principles and build governance into the way AI systems are designed and deployed.

That starts with decision traceability. Every AI-driven output that influences development decisions must be linked to a clear and accessible record of how it was generated.

Human oversight must be structured and enforceable.

Risk classification must be context-specific.

Lifecycle management must be continuous.

Auditability must be built into the system from the beginning.

When these elements are in place, governance stops being a bottleneck.

It becomes an enabler.

 Why This Matters Now

 Regulatory expectations are tightening.

AI adoption is accelerating.

That combination creates a narrow window.

Organizations that operationalize governance early will move faster with confidence.

Those that do not will face increasing friction, regulatory delays, and erosion of trust.

The differentiator will not be access to technology.

It will be the ability to govern it.

Conclusion

AI has the potential to transform biopharmaceutical development.

But transformation without control is not progress.

The current gap between AI capability and governance is not a failure of vision. It is a failure of execution.

Bridging strategy and regulatory science is the critical step.

The question is no longer whether AI can accelerate drug development.

It is whether organizations can operationalize governance at the level required to sustain that acceleration.

 

Author Bio

Matt Hasan, Ph.D., CEO of aiRESULTS

 

Matt Hasan, PhD, is CEO of aiRESULTS and founder of the AI Humanist Movement. He advises Fortune 50 organizations on AI strategy and governance and previously held leadership roles at Deloitte, IBM Global Business Services, and Capgemini.

Farah Hasan, PhD, is a scientist in immunotherapy development with experience at BioNTech, NYU Langone Health, and the Icahn School of Medicine at Mount Sinai.

    References:

    U.S. Food and Drug Administration. Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products (Draft Guidance). U.S. Food and Drug Administration, 2025. https://www.federalregister.gov/documents/2025/01/07/2024-31542/considerations-for-the-use-of-artificial-intelligence-to-support-regulatory-decision-making-for-drug

    European Medicines Agency and Heads of Medicines Agencies. AI Workplan 2023–2028: Artificial Intelligence in Medicines Regulation. European Medicines Agency, 2023. https://www.ema.europa.eu/en/documents/work-programme/multi-annual-artificial-intelligence-workplan-2023-2028-hma-ema-joint-big-data-steering-group_en.pdf

    National Institute of Standards and Technology. AI Risk Management Framework (AI RMF 1.0). U.S. Department of Commerce, 2023. https://doi.org/10.6028/NIST.AI.100-1

    World Health Organization. Ethics and Governance of Artificial Intelligence for Health. World Health Organization, 2021. https://www.who.int/publications/i/item/9789240029200

    Organisation for Economic Co-operation and Development. OECD Principles on Artificial Intelligence. OECD, updated 2024. https://oecd.ai/en/ai-principles

    International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use. ICH Q9(R1): Quality Risk Management. International Council for Harmonisation, 2023. https://database.ich.org/sites/default/files/ICH_Q9(R1)_Guideline_Step4_2022_1219.pdf

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