MONDAY, NOVEMBER 9, 2026
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Oklahoma Law Requires District AI Policies, Parent Opt-Out Rights, Annual Disclosures by 2027-28

A new state law requires all public school districts to adopt AI policies, provide annual disclosures to parents, and allow opt-outs from student-facing AI tools without academic penalty.

A large, classical-style building with a central dome and columns stands under a partly cloudy sky. An American flag flies at half-mast on the left, and several blue flags are visible on both sides of the building.
The Oklahoma State Capitol complex. Shown for state policy context. Photo: Serge Melki from Indianapolis, USA / Wikimedia Commons. CC BY 2.0. Resized for display; social preview adds branding.

The Oklahoma Responsible Technology in Schools Act (SB 1734), which takes effect July 1, 2026, passed the state Senate 42-0 on March 23, 2026. The bill includes an emergency clause.

Annual disclosure and parent opt-out

The law requires each public school district to provide parents and guardians a written disclosure at least once per school year. The disclosure must identify all artificial intelligence tools in use, the vendors supplying them, the categories of student data collected, how much of that data is shared, and the educational purpose of each tool.

Parents may submit a written notice to opt their child out of student-facing AI tools at any time. The district may not penalize the student academically or deny access to core instructional content because of the opt-out.

The statute defines student-facing AI tools as those designed for students that provide AI-generated content, feedback, or assistance during an instructional activity. Classroom AI tools are defined as applications that support instruction, learning activities, assessment assistance, or educator workflows. The opt-out right is limited to student-facing tools.

Additional requirements for AI use

All classroom AI tools must be used under educator direction and with a human in the loop. AI may not be the primary basis for grading, discipline, placement, promotion, retention, or other high-stakes decisions. Student-facing AI must be age-appropriate and have a clearly defined educational purpose. Districts must ensure that the tools comply with FERPA and recognized industry security standards, and must take reasonable steps to minimize the student data shared with AI tools.

District policy adoption deadline

Before the start of the 2027-2028 school year, each district's school board must adopt a policy governing AI and emerging technologies. The policy must address oversight roles, appropriate and prohibited instructional uses, student data protection and minimization, transparency to students and families, periodic review and updates, and compliance with the statute and OSDE guidance.

OSDE model policy and additional notifications

The Oklahoma State Department of Education published a model policy in October 2026 that expands on the statutory requirements. It adds a requirement that families be notified within 30 days when new data-collecting AI tools are introduced during the school year. The model policy also says that districts will provide non-AI instructional alternatives for students who opt out. Districts must be in full compliance by the start of the 2027-2028 school year.

The model policy further requires vendors to comply with FERPA, COPPA, state law, and Oklahoma cybersecurity requirements. Districts must keep a current inventory of AI tools in use and minimize the amount of student data shared with those systems. In the event of a suspected or confirmed data breach, districts must follow their Data Incident Response Plan. The policy includes a provision that shields districts from liability for damages resulting from good-faith AI use.

A shift from voluntary to binding

Earlier OSDE guidance, issued in July 2025, treated transparency and parent notification as recommendations. That version said that parental consent was required for certain AI applications and that districts should publicly disclose AI tools, but it provided no statutory enforcement mechanism and no mandatory district policy deadline. The current statute converts these elements into legally binding requirements.

The OSDE's Version 2.0 guidance also included an AI Acceptable Use Rating Scale with five levels, from no AI use to full AI use with human oversight, each with specific disclosure requirements. The model policy carries forward this framework, though the scale is not codified in the statute.

The OSDE's Version 3.0 guidance, published in July 2026, incorporates the new statute and provides a compliance checklist for districts. The checklist includes approved and prohibited instructional uses, data protection and minimization, family transparency and annual notification, parent opt-out with non-penalization, educator oversight and human review, periodic policy review, incident handling procedures, and procurement and vendor vetting standards.

Implementation ahead

The statute directs the state education department to develop and make available guidance on responsible AI use. It also authorizes the State Board of Education to adopt rules for implementation. The OSDE has posted its revised model policy on its model policies page, noting that the office of legal services has reviewed each policy.

Analysis

Analysis by , written after the reporting above was filed.

Tennessee ran this same requirement in 2024. Districts were still writing policy at the deadline.

Tennessee passed a comparable law in 2024 requiring every district board to adopt an AI policy before that school year. The rollout was uneven. By the July deadline, Johnson City Schools and Rutherford County were still drafting, and several districts had no finalized policy when classes started. Tennessee's law at least required each board to report its compliance to the state every July 1. Oklahoma's statute sets no reporting requirement, so a parent will have to ask their district directly whether it has complied.

No penalty is named for a district that ignores the deadline or skips the disclosure.

The statute authorizes the State Board to "promulgate rules to implement" its provisions but names no consequence for a district that misses the 2027-28 policy deadline or skips the annual parent disclosure. No fine, no accreditation sanction, no reporting back to the state. The OSDE model policy adds a 30-day notification rule for new AI tools and a non-AI alternative for opted-out students, but neither is codified in the statute. A parent whose district disregards these requirements has no statutory remedy named in the bill.

The model policy shields districts from liability for good-faith AI use.

The OSDE model policy, which districts are expected to adopt as their own, includes a provision protecting districts from liability for damages resulting from good-faith AI use. If a district selects a vendor that mishandles student data, that shield could narrow what a parent can recover. The statute requires FERPA compliance and reasonable data minimization, but the liability protection sits on top of those obligations and may insulate the district even when a vendor it chose fails to protect student records.

Sources

  1. Oklahoma Senate / Orrick AI Law Center. Enrolled Senate Bill No. 1734 — An Act relating to schools; creating the Oklahoma Responsible Technology in Schools Act View
  2. Oklahoma State Department of Education. Model Policy Artificial Intelligence (AI) Use in Schools — Updated October 2026 View
  3. Oklahoma State Department of Education. Guidance and Considerations for Using Artificial Intelligence in Oklahoma K-12 Schools, Version 2.0, July 2025 View
  4. Oklahoma State Department of Education. Guidance and Considerations for Using Artificial Intelligence in Oklahoma K-12 Schools, Version 3.0, July 2026 View
  5. Oklahoma State Department of Education. OSDE Model Policies page View
  6. Tennessee Firefly. AI policies are still a work in progress for several Tennessee school districts ahead of 2024-25 school year View
  7. Tennessee General Assembly. HB 1630 — An Act to amend Tennessee Code Annotated, Title 49 (AI policy requirement and annual compliance reporting) View