Adaptive Governance in the Age of AI Regulation: A Constructivist Grounded Theory of School Leaders’ Sense-Making and Institutional Readiness in Implementing DepEd AI Governance Policies

Abstract

This study examined how school leaders interpreted, negotiated, and enacted artificial intelligence (AI) governance policies within Philippine basic education, with particular attention to DepEd Order No. 003, s. 2026. Using a qualitative constructivist grounded theory design, the inquiry involved 10 school-based leaders and program or technology coordinators from selected DepEd school contexts in Occidental Mindoro. Semi-structured interviews served as the primary data source and were analyzed through initial coding, focused coding, constant comparison, memo-writing, category development, theoretical coding, and theoretical integration. Four grounded categories emerged: interpreting and translating DepEd AI governance policy; adapting governance to local conditions and institutional capacity; constructing institutional readiness through capacity building and collaboration; and negotiating ethical tensions, accountability, and stakeholder trust. Participants consistently treated AI as a support tool rather than a replacement for teachers, learners, or human judgment. They described gradual adoption, practical guidance, professional learning, consultation, and locally appropriate safeguards in response to differences in connectivity, devices, teacher readiness, learner access, and organizational resources. Privacy, academic integrity, accuracy, fairness, overreliance, accountability, and equitable access were recurring governance concerns. The study generated the framework Contextualizing Responsible AI Governance Through Adaptive School Leadership, which explains responsible AI governance as a continuing process of policy interpretation, contextual adaptation, institutional capacity building, ethical accountability, and stakeholder collaboration. The findings position school leaders as policy translators, adaptive decision-makers, capacity builders, ethical guardians, and coordinators of shared responsibility in the responsible use of AI in education.