Introductions: The development of artificial intelligence (AI) in countries requires an appropriate governance system and a comprehensive examination of its various dimensions to mitigate issues such as privacy violations, algorithmic discrimination, reduced transparency, weak accountability, and threats to citizens’ rights. In this context, AI governance, as one of the key pillars of digital government transformation, has gradually gained prominence in the upstream policy documents of the Islamic Republic of Iran in recent years. Accordingly, this study aims to analyze the position of AI governance in the national policy-making of the Islamic Republic of Iran and compare it with major international frameworks.

Methodology: This applied study employed a qualitative approach using directed qualitative content analysis and comparative analysis. The research population comprised all official national documents and policy resolutions related to AI governance, smart government, and digital transformation in the Islamic Republic of Iran. The full texts of the relevant documents were examined, and no sampling was conducted. Data were collected through document analysis of upstream policy documents related to smart government, digital transformation, and AI in Iran and were compared with three international frameworks: The Organisation for Economic Co-operation and Development (OECD) AI Principles, the UNESCO Recommendation on the Ethics of Artificial Intelligence, and the European Union Artificial Intelligence Act (EU AI Act). The documents were coded according to predefined AI governance categories, and the findings were analyzed using a comparative matrix.

Findings: The findings identified the major dimensions of AI governance addressed in Iran’s national documents, including legal frameworks, AI ethics, data governance, transparency, accountability, risk management, cybersecurity, privacy, institutional structures, human capital, stakeholder participation, technological infrastructure, innovation, technical standards, and performance evaluation. The results indicate that national documents place considerable emphasis on areas such as human capital development, technological infrastructure, data governance, the digital economy, and institutional structures. In contrast, gaps were identified relative to international frameworks in areas including AI system risk management, algorithmic transparency, explainability of AI-driven decisions, legal liability, AI impact assessment, classification of high-risk AI systems, independent oversight, and citizens’ rights.

Conclusion: The findings indicate that the adoption of the National Artificial Intelligence Document and the Smart Government Roadmap represents a significant milestone in AI policy-making in Iran. For the first time, many components of AI governance—including data infrastructure development, institutional structures, human capital development, smart service delivery, and data governance—have been addressed in a relatively integrated manner in national policy documents. In addition to the National Artificial Intelligence Document and the Smart Government Roadmap, an examination of other upstream national documents shows that, although these documents do not directly address AI governance, they provide many of the institutional, legal, and infrastructural requirements necessary for the development of smart government and the use of AI. The analysis indicates that AI policy-making in Iran has evolved gradually within the broader policy trajectory of digital transformation, e-government, and cyberspace governance. Based on the findings, the development of a comprehensive risk-based AI governance law, the establishment of an independent regulatory body, the implementation of a national assessment and auditing system, the development of regulations concerning data, algorithmic transparency, legal liability, and AI impact assessment, and the strengthening of cooperation among government, the private sector, academia, and international organizations are recommended to foster responsible, transparent, and sustainable AI governance in Iran.