Lessons for Private Entities from MEITY’s Competency Framework for AI Integration

Jasman Dhanoa, Sejal Lahoti | September 2025

INTRODUCTION

The Ministry of Electronics and Information Technology (“MEITY”) has released a report titled “Empowering Public Sector Leadership: A Competency Framework for AI Integration in India” (“Report”). It outlines a competency framework for public sector officials in India to empower them for artificial intelligence (“AI”) integration in the public sector. The Report highlights major challenges with AI, necessitating a holistic approach to governance and competencies.

OVERVIEW

The Report divides the government hierarchy into three levels – policy level officials, mid-level officials, and project implementers, and maps their responsibilities across three broad stages of an AI system’s lifecycle, namely, planning and design, development and deployment, and monitoring and maintenance. It acts as a guide on attributes, skills, and knowledge required from public officials to engage with AI technology. Notably, the Report stresses the importance of the private sector’s expertise in helping the public sector drive innovation through public-private partnerships, expert feedback, and upskilling assistance. The Report advocates imbuing both ethical leadership skills and practical technical skills for public sector officials to enable them to manage risk, data, and security, and make sound decisions that align with the principles of responsible AI.

KEY RECOMMENDATIONS

Foundation and Governance: An AI Governance board for reviewing and authorizing AI applications, overseeing the AI lifecycle, and providing recommendations to ensure AI projects remain aligned with social issues. An AI Ethics Committee to ensure that responsible AI principles are incorporated throughout the lifecycle. The deployment of a standard evaluation tool has also been recommended to evaluate risks from proposed AI systems.
Privacy and Data Management: A special vertical in all ministries to oversee the data lifecycle should be deployed, ‘Privacy by Design’ must be integrated at the development stage, and regular privacy impact evaluations must be undertaken.
Development and Deployment of AI System: Adopting algorithmic impact assessments, transparent procurement practices, stakeholder engagement, collaboration for innovation through public-private partnerships and international cooperation.
Expertise and Public Engagement: Leveraging the expertise of the private sector to upskill public officials through training, workshops, and online courses.
Monitoring, Transparency, and Accountability: Comprehensive documentation of AI models, conducting independent AI audits, a human-inthe- loop approach allowing for human oversight of AI systems, regular AI impact assessments, and post deployment monitoring to course correct.

IMPACT & LESSONS FOR PRIVATE ENTITIES

AI procurement: The Report recommends adopting transparent processes for AI procurement and ensuring that AI solutions procured from third-party vendors respect responsible AI principles. Private entities looking to offer AI solutions to the government must take note of the same.
Ethical considerations: The Report emphasizes responsible and ethical AI use to mitigate concerns of data privacy, cybersecurity, and algorithmic bias. Private entities may also be expected to adopt similar approaches in their AI solutions to align with India’s responsible AI commitments and priorities.
Data management and governance: The Report highlights the importance of data quality, privacy, and security when developing and deploying AI systems. It advocates for the formation of data governance policies and compliance with data protection regulations. Private entities that use data sourced from the public sector may be expected to incorporate such requirements.
Transparency and explainability: The Report discusses the limitations of AI, including its ‘black box’ problem and lack of explainability. To tackle these risks, it recommends maintaining comprehensive documentation of algorithms, datasets, and decision making processes. If a private entity seeks to provide AI solutions to the government, it may be required to comply with extensive documentation requirements.
Stakeholder engagement: The Report recognizes the importance of stakeholder engagement. Private entities, as stakeholders, can expect increased participation in discussions and openness to feedback.
Collaboration in AI R&D: The Report encourages public-private partnerships to promote innovation and spur the growth of ethical AI. The private sector can join the government in its research and development efforts and test out AI solutions for the public sector.
Leveraging expertise for skill development: The Report recognizes the huge gap in AI skilling and looks to the private sector to bridge this gap. The private sector can collaborate with the public sector and contribute to upskilling officials through training, workshops, and online courses.
AI innovation challenges: The Report encourages conducting AI innovation challenges to tackle social problems. Private entities can use this opportunity to leverage their creative problem-solving capabilities to build inroads with the government.
Insight into government priorities: The competency framework gives an insight into the priorities of the government which would help private entities in recalibrating their AI products for the purposes of public procurement.

OUR VIEW

The Report sets implicit expectations for the private sector. The major focus seems to be on responsible AI development to tackle concerns of data privacy, security, transparency, and explainability. Private entities looking to engage with the Indian public sector on AI should imbibe the recommendations made in the Report. The sharp focus on responsible AI development is largely in line with India’s globally projected goals in the AI space. However, certain ideas that seem to have resurfaced, like the AI Governance Board, may stir concerns relating to innovation in the private sector. Overall, the Report serves as an insight into the government’s thinking on any future AI governance regulations.

About Author

Jasman Dhanoa

Jasman Dhanoa is a Senior Associate at ADP Law Offices, where he is an integral member of the advisory team. He earned his degree from Gujarat National Law University. At the Firm, Mr. Dhanoa’s practice is concentrated on providing legal counsel to clients in various sectors, including technology, media and telecommunications, cybersecurity, data protection, artificial intelligence, medical devices, consumer protection, advertising, and privacy law.

Sejal Lahoti

Sejal Lahoti is an associate in the advisory team at ADP Law Offices. She advises clients on issues of data protection, artificial intelligence, electronics, and consumer protection, among others, helping them navigate the regulatory landscape. She graduated from Damodaram Sanjivayya National Law University. Sejal has previously worked with the TMT teams at reputed Delhi NCR and Bengaluru law firms.