Abstract
As generative AI reshapes K-12 education, U.S. states are rapidly developing guidance to navigate its implementation. This study investigates the structural composition of AI education guidance across thirty-five states through qualitative document analysis. Utilizing the CAPE framework and the concepts of policy resilience versus fragility, the research examines how state-level signals influence systemic preparedness for AI education. Findings reveal a landscape of structural fragmentation, where guidance often prioritizes risk mitigation over pedagogical innovation. These early policy choices have potential to shape teacher capacity and sustainability, determining whether AI fulfills its promise of empowerment or widens existing education opportunity gaps.
Introduction
Since the early 21st century, U.S. education policy has pivoted toward accountability, equity-driven reforms, and standardized curriculum. Educators, policymakers, interest groups, and education reformers have invested a significant amount of money, time, and human capital in standardized testing, teacher and student accountability systems, curriculum standards, and funding mechanisms (Heilig & Darling-Hammond, 2008; National Research Council, 2012). States, specifically state education agencies (SEAs), have anchored this evolution, leveraging federal funding to shape local implementation (Childs & Russell, 2017; Russell et al., 2015). However, the rapid acceleration of technology now requires SEAs to navigate an unprecedented digital inflection point: the integration of Artificial Intelligence (AI) into K-12 systems (Pahlka, 2023).
AI is transitioning from a specialized technical skill to a foundational component of 21st‑century readiness (Kundu & Bej, 2025). Driven by the evolution of generative AI and its immediate accessibility, recent federal initiatives and policies have signaled a national priority for K-12 AI education (U.S. Department of Education [ED], 2023). Yet a tension has unfolded between AI technology’s transformative promise of improving students’ academic opportunities and performance (García-Martínez et al., 2023; Song & Wang, 2020), and the risk that uncoordinated, rapid implementation will reinforce systemic inequities rather than dismantle them (Marshall et al., 2025). The federal impetus on AI has propelled a swift and varied response across SEAs. Some states, like Ohio and Oklahoma, have recognized the imperative to equip students and educators for an AI-driven future, and have designed policies to influence school and district readiness related to AI education integration (Ohio Department of Education and Workforce, 2025; Oklahoma State Department of Education, 2025). With the immediacy of AI’s impact on academic integrity and instructional practice, states have rapidly created guidance and policy frameworks for responsible adoption and implementation. Typically, these state guidance documents are non-binding, and serve as heavily weighted directives from the SEA to inform local policy. Additionally, these documents serve as ‘de-facto’ policy guidance, with an expectation that school districts will follow and implement the necessary policies and directives to fidelity. As a result, in recent years many school districts have relied on state-level guidance for developing their local AI education policies, especially as it relates to teaching and learning (Bauschard & Quidwai, 2024).
Within some states, schools and districts are leading policy changes, with limited to no state guidance for how AI will be used as an educational tool within classrooms. In May 2024, only 14.13% of districts across twenty states had formal AI policies (Eutsler et al., 2025). Several districts released their own formal AI policies before their SEA to ensure that their educators had guidance to follow as it relates to teaching and learning within classrooms. For example, Chicago Public Schools AI Guidebook, released in 2025 ahead of any formalized state-level guidance, established a multi-layered framework that promoted the ethical, equitable, and transparent integration of AI. Their AI guidebook provided distinct, actionable guardrails for students, families, educators, vendors, and IT professionals (Chicago Public Schools, 2025). New York City Public Schools AI guidance (2026) outlines a definitive framework that leans on a traffic light system, signaling when AI is prohibited (red list), encouraged (green list), or cautioned (yellow list).
As the primary authorities for public education, states serve as the critical nexus for translating federal priorities into regulatory frameworks. As K-12 AI education evolves within the traditional K-12 system, there is a need for understanding how states’ AI guidance documents influence policy and practice decision-making that affect academic outcomes and opportunities. This study used a qualitative document analysis to investigate the structural composition of K-12 AI guidance across thirty-five states that influenced teaching and learning within state education systems. Applying the CAPE Framework (Fletcher & Warner, 2021), we interrogate how early state-level policy signals are influencing system preparedness for AI, specifically examining how these structures shape teacher capacity gaps, equity, and the sustainability of local implementation. The CAPE Framework, structured around Capacity (infrastructure and educator knowledge), Access (availability of instruction to all students), Participation (who is receiving instruction), and Experience (high quality learning outcomes), provides the empirical scaffolding necessary to evaluate systemic equity through four distinct developmental lenses (McGill et al., 2022; Warner et al., 2022). Our guiding research question was: How do state-level AI education policies foster policy resilience or precipitate policy fragility in their efforts to address systemic inequities and capacity gaps?
The primary contribution of this work is conceptual, introducing a new lens through which to evaluate the sustainability of rapid technological adoption. Our analysis identified the levers within state AI guidance documents that can tilt policy towards fostering institutional policy resilience, characterized by the stable absorption of new priorities, or precipitating policy fragility, where the pace of reform exceeds the infrastructure necessary for sustainability. Policy resilience and policy fragility serve as the conceptual framework for examining the early AI education guidance choices thirty-five states made, such as prioritizing cautious compliance or proactive opportunities. This conceptual framework was developed through a cross-state analysis of states’ novel AI education guidance. Our findings illuminate the potential trajectory for AI education being positioned to either fulfill its promise of empowerment (U.S. Department of Education, Office of Educational Technology, 2023) or further widen existing educational opportunity gaps (Garvin et al., 2024).
The emergence of AI in K-12 has created ethical and educational implications that directly impact student learning (Bulathwela et al., 2024) and have provided opportunities for states to shape policies that substantially impact AI implementation in schools and classrooms. Our conceptual framework allows us to understand the influence and importance of AI guidance, especially as government agencies, business corporations, and non-governmental actors (i.e. nonprofits and faith-based organizations) continue to publish hundreds of AI ethics codes, frameworks, guidance documents, and policy strategies. Understanding the possible directions that states take within AI education provides a pressing and topical case for applying our conceptual model of policy resilience and policy fragility.
This paper first reviews research on AI in education and states’ roles in policy implementation. From this review, we propose an analytical lens linking policy resilience and policy fragility to conceptualize state AI policies, balancing legal protections with pathways for AI to enhance learning. We outline a qualitative methodology to grasp how state guidance alters student learning, even in the absence of legislative changes. The paper concludes with a discussion of the emergence of generative AI and “arrival technology” – technology rapidly entering classrooms without formal adoption (Reich & Dukes, 2025; Smith et al., 2025) – that is impacting student preparedness for a rapidly evolving workforce, and the risks related to reactive policy adoption that could expose the structural fragility of the U.S. educational system due to hasty implementation.
Literature Review
The landscape of computer science education (CSEd) has been driven by the rapid advancement and democratization of AI, which has expanded to become more available and accessible. Additionally, within K-12 education AI has gained increased attention (Childs et al., 2024). While AI has been a CS subfield for decades, the emergence of Generative AI (GenAI) and Large Language Models (LLMs) has shifted the discourse, positioning it as a fundamental instructional tool. GenAI tools, like ChatGPT, have influenced the education field by providing intelligent tutoring systems, assessment and feedback, professional development (PD), support for administrative decision-making, and data analytics for improving academic outcomes (Gillani et al., 2023). Over time, AI has incrementally infused within K-12 classrooms as a vehicle to educate future AI users, designers, software developers, and researchers (Pedró et al., 2019; TeachAI, 2025). As a result, AI in education has transitioned from speculative hype to increased market penetration, as companies and organizations have positioned AI as a support or “teammate” in classroom settings (Shah, 2023). When deployed, AI “agents” can monitor student interactions, suggest collaborative strategies, and even act as a peer to spark debate and critical thinking (Li & Liu, 2025).
The U.S. Department of Education (ED) (2023) highlighted that AI guidance, innovation, and risk management are important dimensions of today’s educational infrastructure. This includes recognizing that AI literacy has become an essential 21st-century competency (Ng et al., 2021). Traditionally, U.S. K-12 education policy adoption tends to be uneven and complex, involving various policy actors, stakeholders, and administrators (Jimerson & Childs, 2017). The AI-in-education environment has evolved rapidly at federal, state, and local levels. In 2024, the National Governors Association provided extensive legal and regulatory AI considerations for states (National Governors Association, 2024). The following year, the White House released an executive order on advancing AI education that provided potential mandates for K-12 AI implementation (U.S. White House, 2025). Soon-after state-level guidance documents emerged from various SEAs, and state legislative reports discussed the evolution of AI-related education policy and its impact on local education systems (Eutsler et al., 2025).
State education policy responses have reflected both challenges and opportunities for AI integration and expansion (Kleiman & Gallagher, 2024). Historically, technology integration has been a cornerstone of modern pedagogy within classroom settings (Ross, 2020). While the early 21st century digital revolution in education prioritized hardware acquisition, focus shifted toward ubiquitous digital services such as learning management systems (LMS), classroom management systems (CMS), and productivity platforms (e.g., Google, Microsoft). Post COVID-19 pandemic investments further expanded the digital landscape, which has led to AI being embedded within in-person, virtual, and online learning environments.
Despite AI’s rapid growth in education, scholarly analysis of state-level guidance remains limited. Recent literature has largely been descriptive, focused on broad ethics or individual case studies rather than systematic, comparative research. This study adds a critical examination of the structural variations across states’ AI education guidance documents and investigates whether “AI for all” rhetoric is supported by actionable equity frameworks. Ultimately, this research provides a foundational benchmark for evaluating the maturity and evolution of AI policy in the K-12 system.
Conceptual Framework
To understand how state-level AI guidance influenced local decision making, teaching, and learning we theorized and proposed policy resilience and policy fragility as a conceptual framework. Drawing on Capano and Woo’s (2017) conceptualization of policies that maintain their core objectives by adjusting to outside pressures and internal disruptions, we apply their concept(s) within the context of education systems. Policy resilience is defined as a process involving anticipation, coping, and adaptation to risks, often relying on resource availability and a diverse knowledge base (Duchek, 2020). In education, policy resilience involves the capacity to absorb new priorities, like AI, without compromising equity, accuracy, or educator capacity. Rather than treating innovation as inherently beneficial, policy resilience emphasizes the systemic stability and resource depth required to sustain equitable access. Conversely, we define policy fragility as instances where reforms outpace the infrastructure or organizational routines necessary to sustain them. Therefore, policy fragility can stem from inadequate long-term planning, volatile funding, or the erosion of PD resources (McLure & Aldridge, 2023). Together, policy resilience and policy fragility serve as an interpretive framework to illuminate how state-level signals shape the conditions for equitable AI implementation at the local level.
Our conceptual framing draws on lessons from prior computing and STEM education reform cycles, where aspirations for modernization exceeded institutional needs (Konstantinidou & Evagorou, 2025) and were in tension with the deprioritization of STEM programming in schools (Marshall et al., 2022). Programs such as the federal CS for All initiative, Project Lead the Way (PLTW), and early virtual learning efforts sought to broaden participation and improve student outcomes through expanded access to innovative programs and technologies (Goode et al., 2018; U.S. Department of Education, Office of Planning, Evaluation, and Policy Development, 2010). Yet the momentum outpaced states’ and districts’ capacity to implement them effectively, resulting in uneven adoption, underprepared educators, and inconsistent student outcomes (Cuban, 2021; Margolis et al., 2008). This gap was exacerbated by reforms like No Child Left Behind, which, at the expense of STEM programming, diverted critical resources and instructional time toward high stakes reading/English Language Arts and mathematics assessments used to deem school’s “success.” Instructional content, PD, teaching and learning, and educational decision-making continue to be influenced by those reforms that focused on students’ academic outcomes (Marshall et al., 2024).
While AI builds upon the foundations of prior STEM and CSEd initiatives, we assert that AI represents a hyper-accelerated reform cycle that departs from these traditional models. Unlike earlier reform models in STEM, AI tools are being integrated into classrooms with a velocity that outpaces established objectives, competency frameworks, or pedagogical preparation (Casal-Otero et al., 2023). This shift necessitates an evolution of the conceptual lenses used in STEM reform (Xu & Fan, 2022). We argue for an adaptation of the subject matter approach (like CSEd) toward a perspective that views AI as a pervasive layer of educational infrastructure (Kim, 2025) that requires both technical proficiency and critical evaluation (Chen et al., 2020; Walter, 2024).
The complexity of modern AI education lies in its identity as both pedagogical and technological, with PLTW serving as a salient example of this duality. PLTW, combined a project-based curriculum with expansive PD to successfully align workforce skills with increased participation among non-white and female students (Hess et al., 2016; Rogers, 2006). Yet the program’s sustainability was constrained by substantial recurring costs (McMullin & Reeve, 2014) that frequently exceeded district budgets and organizational capacity, leading to stratified implementation across schools and districts, reinforcing rather than mitigating inequities. This fragility is a common outcome in STEM implementation, where the cost and complexity of materials (Blocker, 2025) and PD are predictors of program discontinuation and “slippage” in fidelity over time (Durlak & DuPre, 2008; Fixsen et al., 2005). The emergence of AI in education raises similar questions around its cost, complexity, and implementation.
The emergence of AI in K-12 mirrors previous cycles of educational technology (EdTech) implementation. Representing a flourish of promises aimed at making teaching and learning more efficient, cost-effective, and accessible for all (Ross, 2020), EdTech has expanded to include a billion-dollar industry targeting K-12 educators and administrators. However, different from the traditional approaches in EdTech, the policy resilience for AI in K-12 depends on balancing rapid innovation with infrastructure for capacity building, ethical guidance, and equitable access. For example, states that expanded dual credit programs or charter school options within existing accountability frameworks demonstrated resilience by embedding new priorities into established support structures. Conversely, policies driven by rapid adoption, without commensurate investments in training or infrastructure, often expose system fragilities. Early one-to-one technology initiatives exemplify this pattern, revealing systemic fragilities. Despite aiming to democratize access to 21st-century skills, the One Laptop Per Child initiative highlighted that resource disparities often result in shared-use models for the poorest regions while others achieve full coverage. Meaningful implementation required investment in ongoing teacher PD responsive to teacher needs (Karlin et al., 2018). Teachers with substantial training leveraged technology meaningfully, whereas those with fewer supports were less able to align tools with instructional goals (Topper & Lancaster, 2013). The intended benefits of one-to-one initiatives were unevenly realized across and within districts, perpetuating rather than mitigating inequities in students’ learning environments.
The emerging policy discourse surrounding AI education reflects a similar pattern of tension between innovation and capacity: the enthusiasm to integrate AI into K-12 systems is accelerating faster than policies, PD structures, and ethical safeguards required to ensure equitable and sustainable implementation. This research is grounded in the necessity of studying the bridging of the AI implementation gap: the disparity between widespread AI adoption by students and teachers and the governance frameworks meant to guide it. By applying a framework of policy resilience and policy fragility to evolving AI guidance, this study examined not whether states should adopt AI policies, but how the structure of adoption shapes teacher capacity, systemic coherence, and the potential for equitable outcomes. Without robust policy resilience, the innovation of AI risks becoming a layering effect where new tools are superimposed into fragile existing models, potentially accelerating downsides like pedagogical incoherence and data privacy risks. The absence of intentional policy infrastructure risks shifting the burden of ethical oversight onto individual educators who may lack the technical proficiency to mitigate algorithmic bias or protect student data (Alzaharani, 2024). Consequently, documenting the current state of policy is a critical prerequisite for ensuring that AI serves as a tool for educational advancement and equity rather than a catalyst for further systemic disparity.
Factors Driving Policy Resilience and Fragility
To operationalize the concepts of policy resilience and fragility within the domain of AI education, this study posits three interacting factors that serve as primary drivers of systemic stability or collapse during reform cycles: Resource Sustainability, Coherence of Policy Signals, and Distributed Organizational Capacity. These factors determine whether a system absorbs new priorities (resilience) or whether the reform accelerates faster than the supporting infrastructure (fragility). These factors also provide insight on how AI education policies could potentially reproduce systemic inequalities and capacity gaps. We conceptualize these drivers in Table 1 to illustrate the theoretical distinction between policy resilience and policy fragility.
Drivers of Policy Resilience and Fragility.
The interplay of these factors creates a dynamic system, where reforms are often initially fragile due to newness, but can become resilient through strategic institutionalization. Conversely, a previously stable program can become fragile due to external pressures or resource changes. Table 2 includes characteristic examples of systems that have moved from being policy fragile to policy resilient and vice versa.
Movement Between Policy Fragility and Resilience.
The CAPE Framework has been widely employed in computing education research to analyze systemic conditions affecting equity, sustainability, and policy alignment, making it a complement to policy fragility and resilience. CAPE’s four domains (Capacity, Access, Participation, and Experience) serve as the empirical indicators that translate the abstract drivers of resilience into measurable policy components. As a policy design tool, CAPE has highlighted the impact of policy implementation and influence on capacity building efforts (e.g. funding, regulatory approaches, teacher capacity). To operationalize policy resilience/fragility framework in AI education, CAPE is used as a deductive codebook for content analysis.
We propose that the CAPE domains serve as indicators for evaluating AI policy resilience or fragility. In this framework, these are not parallel dimensions but are functionally linked: policy resilience is evidenced when gains in access and participation are matched by a corresponding strengthening of capacity and experience. Conversely, policy fragility occurs through domain fragmentation, where aspirations for modernization, specifically in access, advance more rapidly than the institutional capacity or organizational routines required to sustain them (Table 3). By using CAPE as a deductive framework, we can prioritize exactly which domain is lagging, thereby identifying the specific fracture point of a fragile policy.
Aligning Policy Resilience and Fragility with the CAPE Framework.
Methodology: Cross-State Analysis of AI Guidance
Our research question was, How do state-level AI education policies foster policy resilience or precipitate policy fragility in their efforts to address systemic inequities and capacity gaps? Guided by this question, we conducted a cross-state qualitative document analysis of publicly available AI education guidance documents released from January 2024 through December 2025 to examine how U.S. states conceptualized and structured AI education policy in the early stages of adoption. These documents represent the first wave of state-led efforts to guide expectations for AI literacy, teacher preparation, and ethical safeguards in K-12 education, making them a critical dataset for understanding the emerging AI education policy landscape. By investigating the language and structure of these documents, the study also identified levers that either foster policy resilience or precipitate policy fragility. Given the current absence of codified state legislation regarding AI in education, this analysis utilizes state-level guidance documents, including recommendations or mandates, as a proxy for formal policy. This definition recognizes that in the nascent field of AI education, informal guidance often serves as the primary policy signal that shapes district-level interpretation and implementation before formal legislation is enacted.
Data Sources and Sampling
The dataset consisted of AI guidance documents from the thirty-five U.S. states that had publicly published resources addressing AI in education from January 2024 to December 2025 (Table 4). Official publication was determined by the document’s availability on an SEA website, SEA identification within the text, or its formal announcement through official state communication channels. A total of 994 pages of documents and four web pages were coded and analyzed as text, with state documents ranging from 2 to 81 pages. Web pages were treated as formally completed documents provided they were hosted on official state domains. This constituted a census of eligible documents and categorized as a purposive sampling strategy based on specific inclusion and the availability of official, authoritative policy texts (Mason, 2018). A document was included if it (a) was issued or endorsed by an SEA or equivalent body, defined as documents bearing the official agency seal, authored by state-appointed task forces, or explicitly linked as a primary resource on the SEA’s landing page, (b) explicitly referenced AI or generative AI in relation to teaching and learning, and (c) articulated expectations, recommendations, or parameters for school or district action. Documents that served as secondary support but were not formally sanctioned or branded by the SEA were excluded. The primary unit of analysis was the entire guidance document, while the coding unit was any sentence or paragraph that addressed a conceptual theme.
States Included in Data Set.
The strategic choice to analyze officially published, state-endorsed guidance documents placed priority on authoritative, publicly accessible sources that directly influenced local decision-making and communicated official policy positions. This focus on “as written” guidance documents ensured that the analysis captured the formal, articulated expectations and parameters set by the SEA. By limiting the sample to formally published documents, the methodology adhered to the widely accepted principle of analyzing texts that possess institutional weight and communicative function in the policy ecosystem (Childs & Russell, 2017; Russell et al., 2015). This approach is crucial to policy research, as it offers a robust foundation for understanding the intended scope and official direction of AI integration in public education as opposed to preliminary drafts or non-authoritative internal communications.
Analytical Approach
We posit that CAPE is an effective analytical tool for understanding state-level AI education through a policy resilience and policy fragility lens. Capacity, access, participation, and experience as the four dimensions within CAPE have been applied in examining cross-state CS policy adoption and computing initiatives (Marshall et al., 2025; Garvin et al., 2024) and analyses of systemic inequities in access and computing pathways (McGill et al., 2022). Though originally conceptualized for understanding equity in computing education, CAPE was expanded to encompass policy formation (Warner et al., 2022).
This study utilized a directed content analysis approach (Hsieh & Shannon, 2005) which guided the systematic transformation of raw text into theoretical constructs. In this approach, we used the four CAPE domains as a foundational codebook to organize state guidance: (a) Capacity: Definitions of AI literacy for preparing educators including references to teacher knowledge, PD, institutional readiness, available teachers, and system-level support for responsible AI integration; (b) Access: Descriptions of how AI learning opportunities are allocated, scheduled, staffed or resourced, and any considerations for addressing inequalities across districts or student populations; (c) Participation: Expectations regarding who participates in AI learning, mechanisms for monitoring engagement, and whether AI instruction is positioned as universal or elective; and (d) Experience: Attention to ethical, social, and developmental implications of AI; considerations of data privacy, bias, or transparency; and descriptions of pedagogical or instructional use cases.
Our use of deductive coding aligned with recognized standards for rigorous content analysis, with the goal of evaluating textual data against our conceptual framework (Saldaña, 2021). This methodological approach has been employed in cross-state document-based education policy studies, such as cross-state reviews of STEM and CS standards (CSTA and IACE, 2024; Ekiz-Kiran & Aydin-Gunbatar, 2021) and analyses of district AI or digital learning policies (Eutsler et al., 2025).
A multi-stage analytic strategy was used to strengthen credibility and dependability by ensuring both within-case depth and cross-case comparability. First, documents were reviewed holistically to identify relevant excerpts and classify them into CAPE-aligned categories. Second, cross-case pattern analysis was conducted to identify areas of convergence, divergence, and variation across states. The purpose of the analysis was descriptive rather than evaluative; no scoring, ranking, or normative judgements were applied to states’ guidance documents.
Through the research team’s reflective conversations, it became clear that the AI guidance documents revealed specific policy signals that guide implementation toward either exploring innovative educational opportunities or reinforcing existing legal protections for privacy, integrity, and procurement. After this observation, the research team created a mutually exclusive classification system based on the predominance of policy signals holistically within each document defining caution, opportunity, and balance, which were then applied during a third round of coding.
States were categorized as caution, a reactive posture, when the text focused primarily on risk mitigation, legal compliance, data privacy mandates, and the prohibition of misuse at the expense of pedagogical exploration. Conversely, states were categorized as opportunity when the guidance adopted a proactive posture, framing AI as a catalyst for student agency, instructional integration, and systemic capacity building. This framing often emerges during periods of rapid advancement, when policies or practices are viewed as a panacea to address societal issues or early periods of innovation. For states displaying proportional parity between these two poles, we applied the balanced category, representing a dual-priority approach that simultaneously establishes rigorous guardrails, such as data privacy and ethical oversight, alongside promotion of pedagogical innovation. By utilizing these distinct categories, we provide a critical lens for exploring the spectrum of policy resilience and fragility within AI education.
To mitigate bias and enhance confirmability, a second researcher independently coded a 60% subsample of documents. Codes were documented, cross-checked, and iteratively refined. Coding decisions and discrepancies were discussed through reflexive conversations. This inter-rater discussion informed the interactive refinement of the code definitions and ensured a shared understanding of code application across all documents. In instances of coding divergence, the team engaged in a systematic reconciliation process where disagreements served as a catalyst for refining code boundaries, thereby enhancing the internal consistency and conceptual validity of the analysis. This reflexive approach emphasized transparency and trustworthiness in interpretive analyses of the guidance documents.
Limitations
Several limitations should be considered when interpreting the findings of this study. First, the scope of inquiry is delimited to official state-level guidance. Consequently, the analysis does not capture the nuances of district-level policy development or the localized implementation of these frameworks within specific school contexts. Second, this study represents a snapshot of an exceptionally fluid policy environment, reflecting a specific moment in the rapid evolution of AI education policy rather than a stabilized institutional landscape. Third, the inherent variability in the scope, length, and specificity of the source documents, ranging from broad statements of principle to exhaustive technical handbooks, necessitates caution when drawing comparative inferences based solely on code frequency. This variation, while a finding in itself regarding policy fragmentation, impacts the direct comparability of emphasis across different state contexts. Finally, given the accelerated pace of technological and regulatory updates, some states may have revised their guidance during or immediately following the data collection window, meaning certain findings may not reflect the most current iterations of state-level policy.
Despite these limitations, cross-state document analysis offers a critical first look at how states are interpreting federal AI priorities and transplanting them into educational policy. The approach provides a systematic, theoretically grounded foundation for understanding how early AI guidance positions educators, students, and systems within the rapidly shifting landscape of AI education.
Findings
We present our findings through the CAPE Framework to illustrate the meaningfulness of state-level guidance on AI integration within educational systems. By utilizing the dimensions of capacity, access, participation, and experience, our analysis moved beyond a simple content analysis of what is present in the documents to an evaluation of how these policies might support, or potentially hinder, long-term systemic stability. Our analysis reveals a critical tension in the current policy landscape. While nearly all states acknowledge the transformative potential of AI, their guidance is dichotomized between reactive cautionary postures focused on risk mitigation and proactive opportunity-dominant postures focused on pedagogical innovation. This divergence creates a spectrum of policy resilience where some states provide a cohesive roadmap for integration while others offer fragmented checklists that may leave districts (those responsible for implementation) instructionally vulnerable. Ultimately, this reflects a landscape where states exercise oversight through policy development, while the multifaceted burden of implementation remains a localized district responsibility.
As detailed in the following sections, this tension manifests across the four CAPE dimensions in three critical ways: (1) a technical vs. pedagogical gap in capacity, where states prioritize the procurement of tools and technology vetting over deep educator PD necessary for sustainability; (2) rhetorical vs. operational access, where broad commitments revert to an established EdTech focus on technology distribution over specialized instruction for meaningful intellectual access; and (3) behavioral vs. instructional participation, where engagement is primarily defined through the regulation of academic integrity and student behavior rather than as an instructional milestone.
Capacity
Analysis of state AI guidance documents revealed fragmented policy architecture, where capacity is conceptualized as a series of disconnected compliance tasks rather than a cohesive ecosystem of support. These varied signals distribute attention across risk management and pedagogical enablement, reflecting inconsistent orientations towards implementation. Thirteen state guidance documents adopted a primarily reactive stance, providing reminders on the legal expectations for protecting student privacy and procuring technology, functioning more akin to a risk management checklist. For example, Alabama provided a list of conditions to minimize risk such as complying with the National Institute of Standards and Technology (NSIT) AI Risk Management Framework, conducting an annual audit to ensure compliance, and maintaining a risk register that records AI systems’ relative levels of risk (low, medium, and high). In contrast, twelve proactive guidance documents emphasized ways to leverage the potential of AI to enhance the learning environment. Nevada, for example, celebrates the careful use of AI as “increasingly prevalent in students’ current education experience and in their future professional environments. . .The power of AI tools for education, community engagement and deeper learning will continue to drive innovation and policy” (Nevada Department of Education, 2025, p. 5).
Some documents explicitly suggested that districts foster distributed organizational capacity, suggesting forming a committee of a wide range of users. Others outlined specific, role-based expectations for educator groups. Virginia called out roles and responsibilities for SEAs, governing boards, higher education programs, and AI/technology directors in establishing clear policy. Additionally, West Virginia and Mississippi articulated how AI could meet the specific educational goals of students and educators. Often, documents provided guiding questions to prompt districts toward articulating their pedagogical values and intentions for AI use. Ten of the documents took a balanced approach, equally considering risk and benefit. While Alabama’s guidance emphasizes risk mitigation and compliance with national frameworks, the state also maintains that AI in K-12 schools … will unlock everyone’s potential by catering to individual learning and teaching methods. It will allow students to think critically about AI applications and use them as an aid for research and problem-solving. It will empower our students so they can make significant contributions to society and be change-makers. . .[and] enable educators to cater to the unique learning preferences of each student and guide them to foster a sense of responsibility and empathy toward the ethical use of AI. (Alabama Department of Education & Early Development, 2024, p. 6)
Analysis revealed the underdevelopment of explicit pedagogical capacity and lack of clear examples for how to apply AI in the teaching and learning environments. States that approached their guidance with a lens of opportunity were more likely to include examples of how AI can enhance education by providing clear, situated examples or curricular models for effective AI application. Guidance from both Rhode Island and Washington suggested that students can use AI as a personalized tutor and feedback mechanism to deepen understanding rather than just producing final products. Arizona, Utah, and Wisconsin are examples of states that suggested school leaders leverage AI to streamline operations and analyze data for strategic decision-making. A specific application includes using AI to optimize master schedules, balancing complex variables such as teacher availability, room assignments, and student course requests much faster than manual methods. Administrators can also use AI-powered analytics to process large datasets, such as attendance records, enrollment figures, or academic performance data, to identify trends, forecast future staffing needs, or flag at-risk students for early intervention. The Florida K-12 AI Education Task Force (2025), for example, suggested using AI for administrative and operational support to “to optimize class schedules, bus routes, and facility usage” and that AI “Anticipates fluctuations in student numbers to guide hiring and budgeting” (n.p.).
Despite many states providing clear, situated examples or curricular models for effective AI application, we found that similar to other education policy efforts, there is an implementation gap that places the burden of educator training entirely on local districts, with little support from state authorities. To address the gap, nearly all documents were supported by links to resources from external organizations such as TeachAI and Digital Promise, or state websites that have training or resources.
Definitions
Several states (e.g., Colorado, Indiana, Nevada and West Virginia) used the same verbatim definition of AI education as “the knowledge, skills, and attitudes associated with how AI works, including its principles, concepts, and applications, as well as how to use AI, such as its limitations, implications, and ethical considerations.” Reading across documents, there was consensus that AI education involves:
Fewer states operationalized this definition. Those that leaned into the potential of AI to transform learning tended to offer more explicit examples of application for teachers, students and others in the community. In a few cases, these competencies were specified by grade spans (elementary, middle school, and high school). In some cases, such as Massachusetts, Mississippi, North Carolina, and others, the definition of AI literacy was closely linked to existing Digital Literacy (the use of technology) definitions and standards. Ultimately, these varying approaches suggest that while the definition of AI literacy is still becoming standardized, the path toward integrating it into the classroom remains diverse.
Educator Professional Development
While nearly all state guidance documents explicitly acknowledged the need for educator professional development (PD), the content and scope of these recommendations reveal a fundamental lack of consensus across states regarding the necessary knowledge base for AI education capacity. As a whole, state level AI guidance documents centered the human in all AI interaction, particularly the teacher. Generally, however, the content and scope of recommendations in the guidance documents were highly divergent and fell short of providing guidance for teacher PD with few exceptions. Most states articulated the importance of teacher PD in similar ways to Virginia, which notes “as with any new tool, educators need professional development from experts to feel comfortable and understand both its capabilities and limitations” (Virginia Department of Education, 2024, n.p.), but did not go into detail as to what teachers need to know about AI nor how to teach with AI.
This lack of specificity likely reflects the status of AI as a rapidly evolving technology, where the pace of innovation is faster than PD can be developed and delivered, and outstrips the traditional cycles of policy codification. Unlike established subjects where PD is tied to state-adopted standards and long-standing pedagogical frameworks, AI PD recommendations are currently high-level suggestions rather than prescriptive requirements. The absence of defined requirements creates a vacuum of practice, where local districts are left to interpret high-level ethical goals without a clear pedagogical roadmap.
Though documents typically emphasized the importance of ongoing PD for educators covering ethical use, privacy and bias mitigation, and instruction for students on AI literacy and digital citizenship, states were less likely to define or recommend PD approaches or specific content. Most states approached PD recommendations through a lens closely aligned with traditional EdTech, which focuses on the use of AI tools. For example, Missouri, Colorado, and Alaska, emphasized skills related to integrating AI tools into existing instruction (“learning with AI”). In contrast, states like California, North Carolina, and Indiana adopted an approach aligned with computing education, prioritizing the development of foundational AI literacy, including understanding how AI works, its core concepts, and its social, ethical, and civic impacts.
No state currently has an AI teacher credential, though Virginia, Missouri, and North Carolina have called for the development of a micro-credentialing pathway and Pennsylvania offered guidance on establishing an endorsement. The inclusion of these pathways emerged as a noticeable differentiator in state guidance documents regarding system capacity, providing a formal anchor to standardized teacher expertise. In the context of teacher capacity, formal credentials represent more than just administrative labels; they signify a commitment to deep, rigorous preparation, often requiring significant PD or specialized college-level coursework, that ensures teachers possess the nuanced content and pedagogical expertise to teach both with and about AI. Without clear AI literacy standards and with no credential it is difficult to design AI PD and to get full participation. The absence of formalized credentials contributes to policy fragility by decoupling high-level state guidance from classroom-level implementation, keeping the knowledge base localized and disparate; thus, deepening the divide in student access to high quality education about and with AI across different districts.
Technology
In this context, we define “technology” as a specific digital program, software, application, or platform procured for classroom use, such as generative AI interfaces or automated grading systems. All of the state documents offered guidance on the procurement of AI tools, outlining specific recommendations for procuring and vetting vendor products to provide students and teachers with legally compliant technology. This guidance was highly reminiscent of other education technology efforts where the spotlight is on the tool itself or on using the tool, as opposed to the pedagogy of learning about AI. Kentucky presented a unique perspective in approaching technology, specifically the use of “free” or “freemium” tools. In the section on guiding questions for integration, it recommends reflecting on the following: “If the tool is ‘free’ to use, then am I the payment? (my data, district data, or other datasets of which I have access – beware of freemium models)” (Kentucky Department of Education, 2024, p. 3).
Finally, several state documents addressed the capacity and resources embedded within planet Earth to support AI from an environmental perspective. New Hampshire included a section that detailed the “environmental footprint” of AI, including the energy used to train and run models, the consumption of data centers, and the carbon emissions associated with hardware production and turnover. Montana’s guidance acknowledged that AI systems require “significant energy, materials, water, and contribute to carbon emissions” (Montana Office of Public Instruction, 2025, p. 7). Washington, Florida, Kentucky, Oregon, and Massachusetts are other states that called attention to the environmental impact including the power needed, considering asking vendors about recycling and repairs, and e-waste. Shifting the mental model from AI as another “shiny new thing” to openness to explore AI as a valid and necessary component of modern education will be another way in which districts may need to consider building capacity.
When capacity is viewed collectively, state documents reveal a state-level policy landscape that is currently in tension. While states are establishing a common vocabulary for AI literacy, there is a clear interpretive gap between AI as a technical utility and AI as a pedagogical shift. The preoccupation with procurement and legal vetting, mirroring traditional EdTech frameworks, suggests that many states are treating AI as a plug-and-play tool while other states celebrate AI as a transformative force. This tool-centric approach contributes to structural vulnerability. Without deep teacher preparation or explicit pedagogical models, the system remains fragile: it is technically ready for AI adoption, but instructionally unprepared to sustain it equitably. Conversely, guidance that treats technological infrastructure, teacher expertise, and sustainability as an integrated ecosystem of support rather than an isolated compliance checklist are better positioned for policy resilience. Strong preparation boosts teacher confidence in using the tools effectively, and thus the likelihood of incorporating the tools into their classroom in a meaningful and sustainable way leading to resilience.
Access
While nearly all state guidance documents explicitly called for “all students” to have access to AI learning opportunities, very few included an operational definition of what constitutes “access,” (such as how AI learning opportunities are scheduled, staffed and distributed) or included an implementation strategy to guarantee it. This rhetorical commitment mirrors past EdTech movements, where physical access outpaced instructional support. For example, while the pandemic accelerated device distribution, many districts lacked the training to leverage tools effectively to impact learning outcomes.
When access is discussed, the guidance fragments across three primary equity barriers: digital divide, structural bias in AI, and accommodation. Documents frequently acknowledged the existing digital divide, including lack of internet access or devices, with some states specifically citing disparities of access within rural communities as an area of equitable concern. For example, Colorado estimates nearly 65,000 households “lack consistent access to the internet for educational purposes” (Colorado Department of Education, 2024, p. 15) and Connecticut cautions that “learners without access to technology will fall farther behind in understanding and mastering the use of emerging tools” (Connecticut Commission for Educational Technology, n.d., n.p.).
The second barrier is structural bias in AI. The equity discussion in several states extended beyond technology access to address structural bias embedded within AI systems, emphasizing that equity in access must include caution regarding the algorithms themselves, illustrated by examples in Massachusetts, Connecticut, and Georgia. Finally, access as accommodation was discussed in a small portion of the guidance, including Rhode Island, Mississippi and Colorado, which recommend the use of AI features like scaffolding, speech-to-text, and personalized learning to reach existing instructional goals. This approach is in line with an EdTech’s approach to using tools to learn with AI as opposed to learning about AI (Ng et al., 2021).
Policy recommendations from state guidance documents for addressing access barriers were limited to descriptive tasks rather than prescriptive action. Several states (e.g. North Carolina, Alabama, and Ohio) suggested that districts complete a landscape analysis to better understand where AI is being used, with which tools, and in what ways to support developing policy. More states suggested that this audit focus on auditing access to devices, internet and AI tools to better ensure the digital divide isn’t exacerbated.
The findings within the Access dimension reveal a persistent tension between the rhetorical inclusivity and operational implementation. While state documents adopt the language of “for all,” the guidance remains largely confined to addressing the AI digital divide – the physical presence of devices and connectivity. By focusing on descriptive tasks like landscape audits and technology distribution (devices and/or software tools), states are reverting to an established EdTech playbook that prioritizes physical proximity over the specialized pedagogy required for meaningful intellectual access. This rhetorical-implementation gap signals a state of policy fragility, where the system is technically equipped with tools for adoption, but instructionally unprepared to sustain it equitably.
Participation
Within the CAPE Framework, participation is defined as which students are enrolled in or otherwise receiving CS instruction, typically as a stand-alone course. While the application of AI is frequently conceptualized as a cross-curricular integration across subject areas, the foundational understanding of its underlying mechanics remains rooted in basic CSEd. We adapt this dimension to examine how states define who is engaging with AI and under what conditions, acknowledging this tension between broad usage and specialized technical knowledge.
Most states’ guidance documents focused on acceptable use policies that governed when students may utilize AI and in what manner as it relates to academic integrity. This included disclosure guidance for districts, schools and/or teachers that explicitly defined the acceptable use of AI for assignments and outlined how AI-generated work without proper citations is considered plagiarism (See Missouri, Washington, and West Virginia for examples). Other states, like Utah and Washington, discussed prohibited uses of AI, including the over-reliance on AI that inhibits learning, and the misuse of AI for bullying/harassment (e.g. creating deepfake videos). The strongest guidance across states around misuse was adherence to existing policies and laws, such as data privacy. In particular, states strongly prioritized the protection of personally identifiable information (PII) or confidential data in accordance with state and federal laws, such as the Family Educational Rights and Privacy Act (FERPA) and the Children’s Online Privacy Protection Act (COPPA). State guidance documents consistently converged on the necessity of rigorous vetting protocols to ensure that AI tools have built-in controls to protect sensitive data. Finally, all states recognized the need to center human oversight and adjustment in AI usage. This included users (educators and students) being aware of potential algorithmic bias to make informed decisions about the use and validity of the output. States also called for evaluating AI’s impact on student learning; however, none offer any tools or guidance for how such assessments should be conducted.
These findings reveal a significant shift in how states conceive student engagement with technology with respect to AI. Participation in the AI context is largely defined in state documents through a lens of behavioral regulation and risk mitigation. By focusing primarily on acceptable use policies and academic integrity, state guidance treats participation not as an instructional milestone to be achieved, but as a set of boundaries to be policed. This orientation suggests that states are currently more concerned with governing the manner of student engagement than ensuring the quality or depth of the learning experience itself. When participation is reduced to a list of prohibited uses or vetting protocols, it fails to build the structural capacity needed to foster the foundational understanding of AI mechanics.
Experience, Equity and Ethics
Experience, equity, and ethics were prominent throughout state AI guidance documents. Nearly all state guidance recognized the potential of AI to transform education. State documents marveled at the potential of AI to transform education through improved personalized and adaptive learning. Nevada suggested leveraging AI to enhance personalized competency-based learning which “allows students to advance upon demonstrating mastery of a concept or skill regardless of time, place, or pace, creating a more flexible and student-centered learning environment” (Nevada Department of Education, 2025, p. 24). West Virginia noted AI’s potential for instantaneous feedback and personalized support, particularly for bridging accessibility gaps in underserved regions. Similarly, California highlighted AI’s utility for students with disabilities, such as voice typing, while Oklahoma emphasized its role in providing specialized learning resources to rural districts.
State policies focused on how AI can make it easier to offer multilingual support, either for language development or accessibility of translation. For example, Rhode Island suggested that AI-enabled language support tools and translation can support the design of language instruction that is differentiated for students’ English language proficiency levels, which may help educators leverage a student’s home languages as an asset. This also connected to proposed policies encouraging the use of AI for personalized learning to allow deeper learning and classroom engagement. Colorado emphasized that AI could encourage students to “explore complex concepts and ask thoughtful questions” (Colorado Department of Education, 2024, p. 7), the personalized approach aligning with research-based practices for fostering a deeper understanding and retention of material. It can also automate more basic work in preparation for deep thinking. Louisiana explicitly linked AI use to federal civil rights laws (Title VI and EEOA), stating that AI technologies have the potential to ensure English learners have increased access to meaningful educational experiences. Finally, several states discussed the potential of AI to foster creativity. Colorado continues to describe AI aiding creativity by noting applications to writing, visual arts, and music composition which can “bring students’ imaginative ideas to life” (Colorado Department of Education, 2024, p. 10).
While the promise of AI to transform teaching and learning within schools exists, there are still learning experiences that risk being compromised by AI. All state documents noted that one of the most concerning areas was the inherent bias in AI systems. Algorithmic bias can lead to unfair or discriminatory outcomes that misclassify or inaccurately evaluate students from diverse backgrounds, penalize linguistic differences when automating grading, or unfairly track students through predictive analytics. Massachusetts cautioned that AI can “reproduce the very patterns of exclusion, underrepresentation, and limited access that public education seeks to dismantle” (Massachusetts Department of Elementary and Secondary Education, 2025, p. 24). The Arizona state guidance cited the scholarship of Punya Mishra who “highlighted a concern that most contemporary datasets are WEIRD, that is, they ‘disproportionately represent Western, Educated, Industrialized, Rich, and Democratic societies’” (Arizona Institute for Education and the Economy [AIEE] & Northern Arizona University [NAU], 2025, p. 18).
AI may also create potential mental health challenges. Rhode Island, Oregon, and others cited existing anti-bullying laws and a new potential for violations of these laws through deep fake videos. California also discussed the risk of student isolation particularly if AI replaces the human interaction between educator and student.
All of the state guidance documents emphasized centering the human to mitigate these risks. Washington presented a foundational philosophy of “Human Inquiry → AI → Human Empowerment” which emphasizes that the use of AI always starts and ends with human reflection and insights (Washington Office of Superintendent of Public Instruction, 2024, n.p.). This perspective emphasized learning as an inherently social process which AI might enhance but cannot replace. Furthermore, human intervention was seen as necessary for managing AI’s inherent flaws, including awareness and a critical eye for potentially biased or erroneous output.
Measuring experience within the CS CAPE Framework has proven to be the most systematically challenging, resulting in limited empirical understanding (Dunton et al., 2022; Warner et al., 2022). Assessing an individual’s experience with CS is inherently resource-intensive and time consuming. While it remains to be seen whether measurement of AI experience will diverge significantly from that of CS, the potential of AI to transform learning introduces a greater sense of urgency. Consequently, more systematic methods for assessing student experience are required, such as evaluating progress on broad learning objectives like reading, writing, and mathematics proficiency.
The state guidance documents reveal a paradoxical conceptualization of equity, where AI is viewed simultaneously as a tool for radical inclusion and a catalyst for systemic exclusion. While personalized mastery and multilingual support offer promising avenues for accessibility, these aspirations are tempered by the persistent risk of algorithmic bias. Ultimately, the consistent call for a “human-in-the-loop” philosophy acts as the primary safeguard for policy resilience, anchoring the digital experience in human relationships to prevent student isolation. However, as the field struggles with the resource-intensive nature of qualitative assessment of students’ experiences in AI education, a measurement gap remains. Without systematic ways to evaluate student experience, the promise of human-centered AI risks remaining a rhetorical safeguard rather than a structural reality, leaving the actual quality of engagement unmonitored.
Policy Postures: Caution Vs Opportunity
The nature and purpose of states’ AI guidance, observed through the CAPE Framework, revealed a critical divergence in policy posture: caution and opportunity. As detailed in the methodology, these postures were developed as a mutually exclusive classification system based on the predominance of policy signals identified within each document. This distinction, rather than a simple presence or absence of policy, determined the underlying resilience or fragility of the resulting system. The landscape of state AI guidance was evenly split between the two primary policy postures: caution (n = 13) and opportunity (n = 13). Beyond this divide, a smaller group of states (n = 9) took a more balanced approach.
Guidance that leaned towards caution prioritized compliance, emphasizing restrictive ethical rules, stringent data privacy mandates, and warnings or prohibitions of misuse (as reflected in the reactive capacity and legalistic experience findings). For example, Arizona cautions that “GenAI relies on existing data, its output naturally raises questions about content ownership, copyright, and intellectual property (IP). Current policies and laws may be inadequate to address IP issues generated by a machine” (AIEE & NAU, 2025, p. 19).
While these safeguards provide basic stability, an overemphasis on caution induces policy fragility. By narrowly defining capacity as compliance, this reactive posture fails to cultivate the organizational depth needed for innovation, leaving the system brittle and incapable of adapting to future technological evolution. While caution is warranted, given that AI risks becoming another oversold and underused classroom technology (Cuban, 2021), its nature as an arrival technology requires balancing risk mitigation with proactive capacity-building for thoughtful integration. Crucially, even caution-dominant guidance often mandates educator PD, which serves as an inherent mechanism for policy resilience. By strengthening human capital alongside risk management, these requirements ensure the system can absorb new priorities, preventing a total fracture caused by educator unpreparedness.
Conversely, opportunity-focused guidance framed AI as a catalyst for redefining educational practices. By mandating professional development and prioritizing instructional integration and equitable access, this proactive posture fosters policy resilience. It enhances the system’s structural capacity to incorporate new priorities without compromising educational quality. The key distinction lies not in the presence of capacity-building or equitable access for all students (moving beyond rhetoric), but in the predominance of signals: whether the policy’s primary intent is to merely manage risk or to actively leverage AI for responsible, long-term transformation.
Discussion
Our findings support CAPE’s applicability to statewide computing initiatives (McGill et al., 2022; Warner et al., 2022) and provide a theoretical structure for examining the emerging domain of AI education policy. Themes from our application of the CAPE framework supported our conceptualization of policy resilience and fragility in four distinct ways. First, new K-12 educational initiatives require capacity (Cuban, 2021; Warner et al., 2022), yet our analysis revealed that states diverged in their interpretation and approach of the structural support necessary for implementation and scalability. This fragmentation influences capacity by shifting the interpretive burden from the state to the local level. When guidance is disparate and vague, school districts must expend limited administrative capacity on decoding policy rather than on implementation (Anderson & McKenzie, 2022; Comstock et al., 2022). These variations in depth and clarity create a “capacity tax” where under-resourced districts, lacking the personnel or experience to navigate such ambiguity, default to policy fragility. Thereby hindering sustainability and scalability of initiatives that could benefit students’ academic outcomes and opportunities. Additionally, variations at the state level related to the depth and clarity of AI in education, reinforce policy fragility and create conditions for educators to properly implement technology use policies and infrastructure(s). When state-level guidance documents are divorced from proper resourcing and support, the possibility of policies becoming unfunded mandates or misunderstood become greater (Hodge, 2021).
Second, findings revealed a rhetorical-implementation gap when it came to the primary driver of policy fragility: access. State-level AI guidance documents provided broad equity statements and descriptive tasks rather than prescriptive strategies, shifting the burden of equitable AI integration onto local districts and schools. For district and school-level educators, tasked with scaling AI integration, this could be perceived as a wicked implementation problem (Childs & Lofton, 2021), or as having the illusion of being an equitable policy on paper while potentially widening opportunity gaps (Chu, 2019; Ko et al., 2024). Critically, many states’ AI guidance were based on risk mitigation, focusing on privacy and cheating. While necessary, over-emphasizing risk without providing instructional frameworks limits systemic capacity to compliance-focused models, slowing the development of pedagogical capacity necessary to bridge opportunity gaps. A lack of structural support risks repeating historical EdTech failures where physical proximity to technology (devices) was prioritized over instructional quality (Margolis et al., 2008).
Additionally, our findings showed that participation can be a useful indicator for policy resilience as states implement AI educational policies. When participation increases, it serves as an indicator that the system has moved beyond superficial implementation to a robust state of capacity, characterized by teacher preparation and curricular embedding (Nabi et al., 2025). Systemic capacity is the essential precursor to participation; where educator preparedness and infrastructure are absent, schools are fundamentally unable to offer students responsible or ethical engagement with AI. Participation provides a measurable indicator for understanding how well a policy is being implemented and evaluating impact (Warner et al., 2022), such as who is using AI, AI’s utility, and AI’s impact on student outcomes. Understanding participation’s components of implementation allows for strategic investment in continuous capacity development, which is critical for building policy resilience.
Finally, experience, equity, and ethics are often a key objective of education policy, even when they are vaguely defined by policymakers. The post-COVID-19 schooling era shifted the equity focus to educational policies and practices focused on “all” students with limited recognition of the quality of the experience or clear definitions of what it means for students to demonstrate proficiency in various learning settings (Ciuffetelli Parker & Conversano, 2021). Therefore, experience and equity can sometimes be undertaken more as aspirational goals rather than practical measure(s) of policy resilience and capturing learning outcomes from students’ engagement with teaching & learning. We posit that state-level AI guidance documents illustrate policy resilience as fundamentally tied to a “human-in-the-loop” philosophy (i.e. integrating human thinking, judgement, and decision making within AI) (Wu et al., 2022). By centering human relationships and connectedness, states can build the necessary capacity to examine AI’s potential in education, while mitigating the AI risks that can lead to student isolation, trauma, or harm. Conversely, policy fragility emerges where documents fail to move beyond enthusiastic rhetoric to address data problems and inherent algorithmic bias. Ultimately, the systematic difficulty in measuring qualitative experiences means that unless policies prioritize human-centered oversight and ethical measurement, the promise of an equitable student experience remains a vulnerable aspiration rather than a structural reality.
The CSEd movement showed that access alone cannot reduce inequality, learning, or technological gaps within education (Margolis, et al., 2012; Marshall et al., 2024). As noted by Margolis et al. (2008), intellectual access remains elusive if courses exist only in school catalogs while structural barriers actively inhibit meaningful student engagement. In many states, traditional access metrics have masked underlying policy fragility; for instance, courses may be listed without active student enrollment or a lack of the presence of certified educators necessary to facilitate learning opportunities for all students. These barriers are further compounded by restrictive prerequisites, such as mandated mathematics or science benchmarks (McDaniel et al., 2024), English language proficiency requirements, or subjective teacher recommendations (Hopkins & Weddel, 2024). In the era of AI integration, the education community must move beyond a narrow focus on hardware and tool distribution. Given the risks of unequal infrastructure and professional development in under-resourced districts (Kim, 2025; Nabi et al., 2025), policy must instead prioritize teacher expertise and human-centered care. Rather than viewing AI as a panacea to justify workforce reductions or isolated digital learning, it should be framed as a systemic support to enhance high-quality, equitable learning environments that address the evolving needs of students.
Arrival Technology: Balancing Opportunity and Caution
The integration of AI education is not a simple binary success or failure, but a complex tension between implementation urgency and system preparedness. This tension presents the crucial systemic stressor that tests the policy resilience of education systems responding to the urgency of AI in education while balancing the need to ensure systemic stability. Describing generative AI as an “arrival technology,” Smith et al. (2025) note that it entered classrooms through organic use rather than formal adoption. Consequently, the urgency for integration is driven by external innovation and workforce future-proofing (U. S. Department of Education, 2023; Pahlka, 2023) rather than pedagogical evidence. Unlike traditional initiatives supported by robust research and planning, this external pressure forces states towards rapid adoption. This haste risks compromising systemic stability and program coherence, creating an environment for policy fragility to take hold.
Policy resilience is less about slowing progress and more about aligning pace of implementation with preparation and consideration for educational value. This is particularly challenging in the case of AI where states have rapidly attempted to create meaningful and flexible guidance that supports policymaking for districts and schools (Eutsler et al., 2025). Systemic preparedness, a deliberate investment in educator capacity, technological infrastructure, and ethical frameworks, is essential to foster policy resilience. Intentional preparation ensures that the new AI priority can be absorbed without undermining core educational values or creating immediate implementation gaps. The policy landscape is thus defined by this struggle: the pressure to act swiftly versus the need to plan systematically.
A major finding is that the uneven integration of critical components, specifically teacher preparation, ethical frameworks, and explicit equity language, underscores a high risk of implementing AI education inequitably. This demonstrates a defining characteristic of policy fragility: compromising equity when adopting a new priority. Consistent with earlier CS and STEM reforms, rapid adoption may unintentionally favor well-resourced districts that have the pre-existing capacity, such as funding and PD structures, to absorb and implement policies while supporting teachers (Alzaharani, 2024; Karlin et al., 2018; Topper & Lancaster, 2013). Conversely, under-resourced districts with weaker infrastructure may experience AI as an imposed, techno-solutionist response to labor needs, rather than a supported innovation, which immediately compromises equitable access and widens existing educational gaps (Bulathwela et al., 2024). The structural unevenness confirms that the system’s current capacity is inadequate, making its commitment to equity fundamentally fragile in its commitment to equity. Without deliberate strategy focused on vulnerable districts, including mandated PD and participation metrics, AI policy risks reinforcing rather than disrupting educational inequity.
Implications
Several implications for policymakers, practitioners, and researchers emerged from our analysis, including the need for considering policy resilience and policy fragility when offering state level guidance in emerging technical content areas. Through the context of AI policy design and implementation, a sustained, structural approach rather than the current reactive and fast-paced approach would support a more resilient policy. The methodological approach raises the question of the salience of state-level guidance in supporting district-level policy, particularly when it is vague and unfunded. While cross-state analysis is a valuable tool for mapping intended educational reform (Dunton et al., 2022; Zarch et al., 2024), it ultimately reveals the implementation gap that exists when local education agencies are tasked with translating high-level guidance into classroom-level policy. This review of thirty-five states did little to surface how districts are approaching implementation, but did indicate the priorities of each state by understanding depth and tone (cautious vs. opportunity).
Policy Implications: Structural Integrity Over Speed
Successful AI integration requires prioritizing organizational reflection over rigid mandates. The observed fragmentation in policy signals, particularly the tension between legalistic caution posture and the innovative opportunity posture, underscores the risk of early policy fragility. To build resilience, policy should move beyond compliance checklists to help districts operationalize capacity through localized needs assessments and concrete definitions, shifting focus from vague PD recommendations (capacity) to articulating concrete strategies, timelines, and supports to teach with and about AI. Furthermore, AI guidance should shift from general “access for all” rhetoric toward mandatory mechanisms, such as resource reallocation and human interaction, that directly dismantle identified equity gaps and establish sustainable implementation. Our analysis identifies teacher capacity as a critical, structural equity issue; disparities in teachers’ preparation determine which students have sustained access to rigorous, conceptually grounded AI learning opportunities. To prevent a dual-system risk where only well-resourced districts provide critical AI education, reinforcing uneven policy adoption, school systems should make sustained investments in teacher capacity to ensure a “human in the loop” approach. Currently, AI guidance documents recommend PD aligned with EdTech application (immediate utility) over foundational computing education (conceptual coherence), leading to policy fragmentation: the misalignment of guidance, capacity-building, and implementation expectations across governance levels, resulting in inconsistent and inequitable educational experiences. If teacher preparation remains limited, the structural biases inherent in AI will remain poorly managed, reproducing the exclusion that policies are intended to dismantle. Ultimately, policymakers must recognize capacity as the primary driver of policy resilience and equitable student experience.
Future Research
The current analysis, focused on policy text, reveals several critical voids that require empirical investigation to connect policy intentions to actual outcomes. Future research should move beyond document analysis to examine how state guidance is engaged at the local level. A critical line of inquiry is the comparison of implementation phases in states with strong local control versus those with strong centralized authority, investigating how districts interpret and execute guidance that lacks prescriptive mandates. Furthermore, empirical studies should track the evolution of structural support over time, focusing on how PD initiatives and district-level adaptations change in subsequent phases of AI education implementation. This includes gathering longitudinal data on whether reliance on external funding models and resources evolves into sustained local investment, providing crucial insight into the progression from immediate resource dependency to long-term resource sustainability.
Crucially, the current analysis does not address how guidance is enacted by individual educators or how AI deployment affects instruction, student learning, or teacher workload. Empirical measures of AI teaching and learning remain underdeveloped. Future research is needed to develop instruments and methodologies that can (a) connect policy intentions (e.g., the call for “critical evaluation”) to observable classroom practice and student outcomes and (b) evaluate the true impact of AI on learning, including both its cognitive benefits and the potential risks to foundational skills or student agency.
Ultimately, rather than advocating for specific policy actions in the current uncertain environment, our findings underscore the paramount importance of deliberate pacing, clear ethical framing, and inclusive capacity-building as the core principles for designing resilient AI education policy. Recommendations for AI policy need to remain flexible until the field has good use cases for AI in education and empirical evidence demonstrating whether and how AI improves teaching and learning is available.
Conclusion
The integration of AI into K-12 education is currently defined by a fundamental tension: the urgency of technological and pedagogical adoption versus the reality of systemic preparedness. Our cross-state analysis, framed by the concepts of policy resilience and policy fragility, reveals that the pace of AI policy adoption is the critical stressor that will determine whether AI education fulfills its transformative promise or becomes another cycle of under-sustained reform, potentially perpetuating equity and capacity gaps.
Driven by a rapid federal push and the perceived need to future-proof the workforce, many states have pushed swift policy guidance. This urgency, however, risks introducing policy fragility by compromising existing program coherence and stability when not matched with corresponding investments in capacity. Conversely, achieving policy resilience demands a more deliberate, systemic approach. It requires a sustained commitment to:
Crucially, state guidance reflects a divergence in approach characterized by caution versus opportunity. Caution-dominant policies, which focus primarily on compliance, ethical prohibitions, and risk management, provide a necessary, immediate safeguard but risk long-term brittleness by limiting the cultivation of distributed capacity for innovation. In contrast, opportunity-focused policies actively build systemic strength. By providing resources to support mandated PD, explicit instructional integration, and a clear commitment to equitable access as a central objective, these policies are directly contributing to the potential for durable, long-term resilience required to sustain AI education.
Ultimately, the findings indicate that the path forward for state AI policy is not about slowing progress, but about aligning the pace of implementation with system capacity. By identifying the current fragmentation in policy signals, this study answers how state-level guidance risks reproducing systemic inequities, primarily through a reliance on reactive compliance rather than proactive, structural support. To ensure AI education serves as a mechanism for universal empowerment and not a multiplier of existing inequities, states must resist the lure of short-term “wins” and systematically invest in the infrastructure, teacher preparation, research, and equity frameworks that forge a resilient educational future.
Footnotes
Funding
The authors disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This work is supported, in part, by the U.S. National Science Foundation (NSF) under Grant No. 2417664. Any opinions, findings, and recommendations expressed are those of the authors and do not necessarily reflect the views of the NSF.
Declaration of Conflicting Interests
The authors declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.
