backThe ethical governance of artificial intelligence (AI) has gained accelerated relevance in the Brazilian legal and regulatory landscape, especially with the advancement of Bill No. 2338/2023 and the imminent AI regulation in the European Union (AI Act). In this context, the AI Ethics as a Service model emerges as a strategic solution for organizations seeking to develop, procure, or use AI systems with safety, responsibility, and legal compliance.
This article aims to clarify the concept of AI Ethics as a Service, its benefits and challenges, and how law firms specialized in this field can operate within this model to support their clients.
What is AI Ethics as a Service?
Inspired by the already established DPO as a Service model, AI Ethics as a Service refers to the outsourcing of ethical governance and regulatory risk assessment of AI systems. This is performed by professionals or specialized committees who evaluate risks, define internal policies, and oversee the lifecycle of AI solutions within organizations.
This service includes, among other activities:
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Risk classification of AI systems (minimal, limited, high, or prohibited);
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Execution of AI Impact Assessments;
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Support in drafting internal policies and contractual provisions;
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Mediation of decisions by the AI Ethics Committee;
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Ongoing monitoring of performance and compliance;
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Strategic advisory based on principles such as human autonomy, transparency, non-discrimination, safety, and accountability.
Benefits of AI Ethics as a Service
1. Regulatory Compliance
Beyond proposed legislation such as Brazil’s Bill No. 2338/2023 and the EU AI Act, the use of AI systems in Brazil is already subject to existing and fully enforceable legal frameworks, particularly in areas such as data protection, intellectual property, and civil liability.
For example, the General Data Protection Law (LGPD) imposes strict obligations on the processing of personal data—including when operated by algorithms or automated models. AI use must adhere to principles such as purpose limitation, necessity, security, transparency, and accountability. It also requires the identification of the appropriate legal basis and mitigation of risks like discriminatory decisions, excessive data collection, or violations of data subject rights.
Additionally, intellectual property law (including copyright and software laws) establishes clear limitations on the reuse of protected works, including for the training and use of generative AI models. The use of textual material, images, code, or any protected asset may require appropriate licensing and recognition of rights holders—calling for careful contractual, technical, and legal oversight.
In this landscape, AI Ethics as a Service provides organizations with the support needed to ensure:
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Legal compliance in the reuse of personal data and protected assets, including proper application of LGPD, copyright laws, and other relevant regulatory frameworks;
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Risk assessment in the development or implementation of AI algorithms;
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Prevention of litigation and sanctions through structured controls, impact assessments, and qualified legal opinions.
This approach ensures that companies not only anticipate future AI regulations but also proactively comply with currently enforceable laws.
2. Structuring AI Ethics Committees
Outsourcing may include the technical coordination or even the chairing of an internal AI Ethics Committee, ensuring independence and multidisciplinary representation. The Data Protection Officer (DPO) or DPO as a Service provider may assume a leadership role in such a committee, supported by technical, legal, and compliance teams.
3. Risk and Liability Mitigation
Specialized oversight enables early identification of ethical and legal risks, even during the planning or procurement phase of AI tools—preventing misuse of sensitive data, algorithmic bias, wrongful automated decisions, and contractual breaches.
4. Education and Organizational Culture
Specialized professionals contribute to the ongoing training of staff, the drafting of tailored internal policies, and the promotion of a culture of ethical and responsible AI use—essential for organizations that value integrity and sustainability. The AI Ethics as a Service model may also support the delivery of internal training on the responsible use of AI within the organization.
5. Flexibility and Scalability
The service can be tailored to the organization’s digital maturity and the complexity of the AI systems involved. It may be contracted for specific projects or structured as a continuous advisory model (e.g., committees, periodic assessments, training sessions), depending on organizational needs.
Final Considerations
The AI Ethics as a Service model represents a natural evolution for organizations seeking to adopt AI solutions with responsibility, legal security, and robust risk governance. In addition to addressing emerging regulatory demands, this model reinforces institutional reputation and prepares businesses for a more rigorous compliance environment.
Campos Thomaz Advogados, as a law firm specialized in Technology Law and Data Protection, is fully equipped to support its clients in adopting and operating under the AI Ethics as a Service model, aligned with market demands and global best practices in the field.
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