Operationalising Human-Centred AI Governance Under the EU AI Act: A Governance Framework for Human Oversight and Data Accountability

Abstract

Artificial intelligence (AI) is increasingly embedded in high-stakes socio-technical systems, intensifying concerns about autonomy, accountability, data rights, and fundamental-rights protection. This article develops an exploratory, expert-informed Human-Centred AI (HCAI) pre-design governance framework that translates selected risk-based obligations of the EU Artificial Intelligence Act into early organisational decisions about human oversight, data accountability, documentation, and bounded algorithmic autonomy. Using a sequential mixed-methods design, the study combines an Analytic Hierarchy Process (AHP) survey of 28 experts with think-aloud interviews with 15 of those respondents. The AHP results show that, among the governance criteria included in the model, AI design objectives received the highest upper-level priority and human oversight and control received the highest global priority, followed by personal information protection, design ethics, intellectual property rights protection, and limits of algorithmic autonomy. The interviews explain these priorities by showing that experts framed trustworthy AI governance as a problem of controllability, responsibility allocation, traceable data use, rights protection, and verifiable human intervention rather than model performance alone. The study contributes by defining pre-design governance as a bounded initial consideration-stage decision structure, combining AHP-based priority evidence with qualitative justification logic, and proposing a preliminary governance package of decision points, minimum evidence artefacts, and illustrative operational check criteria. The package is not presented as a validated legal compliance model; instead, it provides an expert-informed translation pathway for future organisational, sector-specific, and empirical validation.