Tracking AI Disclosures Across Corporate America
February 20, 2026
Joyce Chen
Companies are moving beyond experimental uses of artificial intelligence (AI) and embedding it more deeply into their operations to improve productivity. After an initial wave centered on automation and content generation using generative AI, organizations are now beginning to explore agentic AI, systems designed to carry out more sophisticated, multi-step workflows with minimal human oversight.
This evolution is enabling companies to reimagine how work gets done, with AI taking on a more active role across business functions and continuously adapting to company needs. At the same time, increased autonomy is casting a large spotlight on governance frameworks and risk controls, as AI becomes a more influential part of day-to-day decision-making.
Throughout the 2026 proxy season, Equilar will track AI governance disclosures as they are filed. This segment features prime examples of AI disclosures and will be updated regularly during proxy season.
PALO ALTO NETWORKS
Global cybersecurity company Palo Alto Networks referenced its artificial intelligence governance framework by citing its “Responsible Use of Artificial Intelligence Policy,” which outlines six core principles that shape how AI technologies are designed and used across its products and services. The full policy is found on their website, highlighting their "Responsible AI Principles" and Responsible AI Framework."
Palo Alto Networks, Inc. (PANW) DEF14A — Filed on November 7, 2025
INTUIT
Leading global financial technology company Intuit disclosed a commitment to developing and using AI responsibly and ethically. This approach is guided by six responsible AI principles: Powering Prosperity, Accountability, Enhancing Human Talent, Transparency, Fairness, and Privacy and Security. All six of these principles collectively shape the Company’s AI-driven platform and are embedded through a structured, multi-layered AI governance framework.
The Intuit AI governance structure operates across four interconnected levels: the board of directors and its audit and risk committee, an AI governance committee, a dedicated responsible AI team and Intuit employees. Together, these groups provide oversight, accountability and checks and balances to ensure AI is developed and used in alignment with the Company’s responsible AI standards.
Intuit (INTU) — DEF14A Filed on November 26, 2025
VISA
Visa has long incorporated artificial intelligence into its business, with AI governance integrated into the Company’s broader risk management and strategic planning processes. The Company’s proxy disclosed that the board provides overarching oversight, while the audit and risk committee focuses specifically on AI-related risks. Visa states that, together, its governance framework and corporate values support the responsible use of AI.
Visa (V) DEF14A — Filed on December 8, 2025
ACCENTURE
Professional services company Accenture provided disclosure specific to how its audit committee regularly oversees AI-related matters. This includes interpreting risk exposures and providing updates to the board on these topics. The Company also maintains a formal Responsible AI compliance program that applies to both its internal AI systems and client services, guided by nine key principles. As AI continues to evolve, Accenture states it will regularly update this program and support it with responsible AI training across its workforce, along with more specialized training for teams that develop or deploy AI solutions.
Accenture (ACN) DEF14A — Filed on December 12, 2025
PENGUIN SOLUTIONS
Information technology services company Penguin Solutions disclosed the use of AI as part of its broader technology and security operations, with oversight centralized under the board’s cybersecurity and technology risk management committee. The committee specifically oversees how generative AI tools are implemented and managed to ensure they align with the Company’s ethical standards, regulatory requirements and strategic objectives.
Penguin Solutions, Inc. (PENG) DEF14A — Filed on December 19, 2025
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Joyce Chen
Associate Editor at Equilar
Joyce Chen, Associate Editor at Equilar, authored this post. Andrew Gordon, Senior Director of Research Services, provided data and analysis. Please contact Amit Batish, Senior Director of Content & Communications, at abatish@equilar.com for more information on Equilar research and data analysis.