The university maintains a set of instruments that are revised regularly: an AI guide, recommendations for action, a service agreement on the use of AI systems, and a register of processing activities. The combination places advisory guidance and data protection documentation in the same institutional package.
Governance, Strategy and Policy
The curated records of Task 2.2. The account view reads them grouped by level and domain; the database view opens the same records for filtering, sorting and downloading.
Meso
Institutional governance7 practicesA policy issued by the rector in April 2024 is accompanied by instructions for using AI-based applications in studies. Issuing the instrument at rectoral level gives it institution-wide reach rather than leaving adoption to individual faculties.
A framework introduced in 2025 provides internal guidelines for integrating AI across educational, administrative and support services, with the stated aim of turning the university into an AI-enabled institution. It answers the gap left a year earlier, when policy was still under discussion and the decision was delegated to individual teachers.
An AI committee was established alongside pilot tests of tools in learning design and IT support and seminars for staff, students and the general public. Extending the seminars beyond the university is unusual in the partnership and treats AI literacy as a public rather than an internal concern.
While institution-wide policy was still under discussion, the university adopted an interim rule under which each teacher decides the level at which AI may be applied in learning activities and may rule it out entirely. The arrangement keeps courses operating during a policy vacuum at the cost of leaving students facing different rules in different courses.
A steering committee covering the whole institution was installed in October 2024, at a point when the university reported no institutional practices in place. The sequence constitutes a finding in itself, in that the governance structure was established before any application had been deployed.
A working group was set up to develop an institution-wide AI policy and guidelines, with availability announced for 2026. Recording the group rather than the policy is itself the finding: in the second round the institution had teacher guidelines but no institutional instrument.
Macro
National policy10 practicesA government action plan published in January 2025 sets out a roadmap for maximising the potential of AI across the country. Recorded as a change in nationwide practice rather than in policy, it marks the point at which the national conversation shifts from regulation towards deployment.
The conference of Spanish rectors published recommendations covering opportunities, risks, ethics and evaluation. The document is not law but guides the university system, and it explicitly delegates implementation to individual universities while proposing shared principles, competence definitions, internal discussion processes, equity of access and an assessment of ecological cost.
A draft law approved by the government in March 2025 aligns national provision with the EU AI Act. Its appearance in the second round is one of the clearest instances of European regulation propagating into national legislation during the observation period.
Material published in April 2025 by the national agency for education and the ministry gathers legislation and recommendations for 2025, prepared with practitioners, researchers and other stakeholders. The partner records the policies it contains as advisory rather than binding.
A national task force was established and seminars and workshops on generative AI and large language models in education were held. The pairing of a committee with public events is the shape national activity takes where no education-specific framework yet exists.
Guidelines for the confederation were published on 1 July 2025 and a report on AI in education followed a day later. In a partnership where the previous round recorded no national policy at all for this country, the appearance of two instruments within two days marks a distinct change of pace.
Respondents describe a framework in which the European AI Act operates together with recent national legislation of September 2025, ministerial guidelines for schools and a national AI strategy covering 2024 to 2026. The layering of European and national instruments is what respondents themselves report as governing use.
An administrator describes a national framework combining the national AI strategy, an AI in education policy document and action plan for 2025 to 2029, and generative AI guidelines from the research council. The same account states that no fully standardised regulation for generative AI in education exists, leaving universities responsible for their own institutional policies.
The regulation is the single most frequently named instrument across countries in the third round, cited by respondents regardless of where they work. It functions as the common reference layer beneath national frameworks that otherwise differ widely in form and force.
A support staff respondent reports that the European regulation takes effect nationally on 2 August 2026 while its prohibitions already apply. The distinction between staged application and full entry into force is what institutions have to plan against.