Managed Security Services: CISO Does Not Bear Sole Liability
Benedikt Langer
8 min. read In many organisations, the CISO is seen as the person who stands accountable for security. ...
6 min read
78 percent of all employees use AI tools that their IT departments have not approved. This is not a prediction-it’s the documented status quo in companies worldwide. Within 18 months, Shadow AI has evolved from a fringe phenomenon into the largest uncontrolled technology adoption in corporate history. The question is no longer whether employees are using generative AI, but how organizations should respond to the fact that they already are.
Definition
Shadow AI refers to employees’ use of AI tools and services without the knowledge, approval, or oversight of the IT department. Unlike traditional shadow IT, shadow AI affects not only infrastructure but directly impacts the processing of sensitive corporate data and the quality of decision-making processes.
Shadow IT was an infrastructure problem. Employees installed Dropbox, used private cloud services, or set up their own collaboration tools because the IT department was too slow. The risks were manageable: unpatched software, unsecured endpoints, missing backups. IT could catch up, offer alternatives, and bring most shadow services back into the controlled perimeter.
Shadow AI is fundamentally different. It’s not about software installation-it’s about real-time data leakage. Every input into ChatGPT, Claude, Gemini, or Copilot is potentially a data breach. Draft contracts, customer lists, strategy documents, source code, financial data-everything ends up on servers that the company neither controls nor can audit. And unlike a file in Dropbox, once it’s out, there’s no retrieving it.
The crucial difference: shadow IT affected infrastructure. Shadow AI affects decision-making. When an employee lets an AI model revise a contract draft, they’re implicitly delegating legal judgment to a system with no liability and no contextual understanding. When a financial controller runs sensitive data through an external AI model, confidential information leaves the secure perimeter-permanently.
Compounding the issue is the speed of adoption. It took years for Dropbox to spread across enterprises. ChatGPT reached 100 million users in just two months. IT departments had no time to establish policies before usage became routine.
There’s also a regulatory dimension that shadow IT never had. Under the GDPR, any processing of personal data by third parties requires explicit authorization. NIS2 tightens obligations for critical and important entities. The EU AI Act introduces additional requirements for documenting AI use within organizations. If a company doesn’t know which AI tools its employees are using, it cannot meet any of these legal obligations. Shadow AI is therefore not just a security risk-it’s a tangible liability threat.
Multiple independent surveys from 2025 paint a consistent picture. The WalkMe State of Digital Adoption Survey polled over 3,500 knowledge workers worldwide. The result: 78 percent openly admit to using AI tools their employer has not approved. The November 2025 UpGuard study reports an even higher figure: over 80 percent of respondents use unauthorized AI tools in their daily work.
Even more striking: usage increases with seniority. According to UpGuard, executives use unauthorized AI tools more frequently than their teams. 69 percent of C-suite executives and 66 percent of senior vice presidents see no issue with prioritizing speed over data privacy. The message is thus clearly communicated downward-even if never spoken aloud.
Knowledge-intensive departments are particularly affected. Marketing teams use AI for content creation and campaign ideation. Legal departments summarize contracts. Finance teams analyze data. HR generates job postings and performance review templates. Usage is widespread, deeply embedded, and in most cases completely invisible to IT departments and their monitoring systems.
A BlackFog investigation adds another dimension: 60 percent of employees say they are willing to accept security risks to meet deadlines. For many, AI tools are the go-to solution for staying productive under pressure. This is not malicious circumvention-it’s rational self-help in organizations that offer no viable alternatives.
Across industries, a pattern emerges: the more regulated the sector, the wider the gap between official policy and actual usage. Financial services, insurers, and healthcare providers often have the strictest bans-and simultaneously the highest rates of shadow AI adoption. Productivity gains are immediately tangible for employees, while risks remain abstract and delayed. As long as this asymmetry persists, every prohibition will be bypassed.
Software AG’s 2025 survey delivered a data point that calls the entire strategy of prohibition into question: 46 percent of employees say they will continue using unauthorized AI tools even if their company explicitly bans them. This isn’t rebellion or defiance-it’s rational behavior from people who want to do their jobs more efficiently and haven’t been given an approved alternative.
The parallel to shadow IT in the 2010s is instructive. Back then, IT departments tried to block cloud services. The result? Employees switched to private devices and personal accounts. The problem wasn’t solved-it was simply driven underground. The same thing is happening now with AI. According to the WalkMe survey, 58 percent of employees are already accessing AI tools via personal devices or private accounts.
Bans actually increase risk. When employees aren’t allowed to use tools officially, they won’t ask whether it’s permissible to input certain data. There’s no point of contact, no policy, no escalation path. Usage continues anyway-just without oversight, without logging, and without any way to trace what happened in the event of a breach.
Prohibition doesn’t create compliance. It creates opacity. And opacity is the exact opposite of what organizations need when 78 percent of their workforce interacts with external AI systems daily.
There’s another consequence often overlooked in the debate: bans harm competitiveness. Companies that impose blanket bans on AI use lose twice. They forgo productivity gains that their competitors are already realizing. And they signal to job candidates and current staff that the organization is technologically backward. In a labor market where AI proficiency is increasingly seen as a basic qualification, this disadvantage quickly translates into higher turnover-and, over time, a growing innovation gap.
These three figures capture the core of the problem in stark clarity. Seventy percent of organizations are aware that their employees use generative AI. Yet only 15 percent have responded by implementing formal governance policies. At the same time, according to a joint study by CybSafe and the National Cybersecurity Alliance, 38 percent of employees are already sharing sensitive corporate data with external AI platforms-without any authorization.
The financial implications are substantial. Gartner forecasts that by 2027, 40 percent of enterprises will experience security incidents directly tied to shadow AI. Industry surveys indicate the average incremental cost of such incidents is approximately $670,000 compared to conventional breaches.
Yet financial losses represent only the visible tip of the iceberg. The real damage lies in the erosion of data sovereignty. Data entered into an external AI model cannot be retrieved. Training cycles, caching mechanisms, and vendor server logs are entirely beyond the organization’s control. What appears today as a harmless productivity tool could tomorrow constitute a compliance violation under GDPR or NIS2. In regulated sectors such as financial services or healthcare, the stakes are even higher: in addition to fines, professionals may face employment bans and personal liability.
Companies successfully curbing Shadow AI don’t rely on technology alone. They combine three interdependent levers. None of the three is sufficient in isolation, but together they fundamentally shift the dynamics.
First: Provide approved alternatives before imposing bans. Any organization that bans ChatGPT without offering an internal alternative has already lost. Enterprise-grade AI tools with single sign-on, data-loss prevention, and full audit logging are now the minimum standard. The user experience must be at least equivalent. Employees don’t turn to personal tools by principle-they do so because the corporate tool is slower, more limited, or simply unavailable.
Second: Establish usage policies instead of outright bans. An effective AI governance policy doesn’t just define what’s prohibited-it specifies how AI tools should be used safely. Which data classifications may be entered into which tools? Who verifies AI-generated outputs before business-critical decisions are made? Where does liability lie in the case of erroneous AI results? According to WalkMe, only 32 percent of employees have so far received formal AI training. This gap can be closed faster than any technical control system can be implemented.
Third: Ensure visibility. Shadow AI discovery tools and SaaS management platforms identify which AI services are being used across the corporate network-not to punish, but to enable informed decision-making. If you know the marketing team is entering customer data daily into an unauthorized tool, you can respond proactively. If you don’t, you’ll likely only find out during a security incident or the next GDPR audit.
Order matters: visibility first, then policies, then secure alternatives. Anyone who starts with a ban has already lost, because they merely push the problem out of sight.
The strategic advantage of effective AI governance goes beyond risk reduction. Organizations that equip their employees with secure, high-performance AI tools simultaneously collect usage data revealing where AI delivers the greatest impact. This data becomes the foundation for targeted investments, automation decisions, and the next generation of productivity tools. Those who channel Shadow AI into structured frameworks don’t just reduce risk-they build proprietary knowledge their competitors lack.
Shadow AI refers to employees using AI tools and services without the knowledge or approval of the IT department. This includes public platforms such as ChatGPT, Claude, Gemini, or Midjourney accessed via personal accounts, private devices, or web browsers.
Shadow IT primarily involved infrastructure-unauthorized software or cloud services. Shadow AI, by contrast, directly impacts the processing of sensitive data and the integrity of decision-making processes. Every input into an external AI tool carries the risk of an irreversible data leak.
Between 71 and 80 percent, depending on the study. WalkMe’s 2025 survey puts the figure at 78 percent, while the UpGuard study reports over 80 percent. Notably, usage rates increase with seniority level.
No. Forty-six percent of employees say they would continue using unauthorized AI tools even if explicitly prohibited. Fifty-eight percent switch to personal devices and accounts. Bans create opacity rather than compliance.
Security incidents involving Shadow AI cost an average of approximately $670,000 more than conventional breaches. Gartner predicts that 40 percent of organizations will be affected by such incidents by 2027.
Header image source: Pexels / Sora Shimazaki (px:5935787)