From the K–12 edition of October 22, 2026
Frederick County Public Schools (MD) adopts Regulation 124-01 implementing its student AI ban: approval paths, no AI grading, no detector-led discipline, vendor contract terms
Frederick County Public Schools (Maryland) · K-12 district AI regulation: student access, staff and operational use, procurement and data security · Frederick County, Maryland, United States
- Publisher
- Frederick County Public Schools Legal Services
- Original publication
- Regulation 124-01 adoption date 10/22/26 (regulation history); Policy 124 revision date 10/22/26
- Source retrieved
- 2026-10-23
- Event date
- 2026-10-22
What happened
On October 22, 2026, the day of Maryland's AI Ready Schools Act deadline, FCPS adopted Regulation 124-01 and revised Policy 124 to reference it. The regulation keeps the PreK-12 student ban on AI products but defines approval paths: courses where the curriculum office says AI is required, AI literacy lessons, IEP or 504 plans when other assistive technology is unavailable, and other uses approved by curriculum and IT. Approved tools must be on the Approved Digital Tool List and reachable only after sign-in to the FCPS network, with inputs and outputs subject to monitoring. Prohibited uses include entering student or employee PII without a data-sharing agreement, AI making consequential decisions on its own, and staff grading learning tasks with AI outside approved computer-scored platforms. Staff may not rely on AI detectors as the primary integrity tool. Annual AI literacy is required for grades 2-12 and annual role-specific staff training. Procurement must evaluate ten criteria, including whether FCPS data trains vendor models and total cost of ownership; contracts must limit data use and prohibit advertising, profiling and unrelated model training. Operational AI affecting student services must be bias-evaluated before adoption.
Why it matters
The most detailed primary implementation text yet from a Maryland district at the state deadline; it turns a headline ban into specific access, procurement, oversight and incident-reporting rules that vendors and integrators will have to meet.
Evidence and measured results
Primary regulation text, opened in full. It is a rule set, not an evaluation; no data on usage, approvals or outcomes.
Limitations and uncertainty
Adopted text only; how approvals, monitoring and enforcement work in practice is not yet known. The regulation's history lists adoption on 10/22/26, but no board minutes or press coverage of the adoption were opened. The earlier Policy 124 adoption (October 7) is already archived; this record covers the new regulation, which is a separate document.
Put this evidence to work
Lighthouse Advisory interpretation, grounded in this source. Enriched 2026-10-22; this does not change the original publication date. Each role follows the same checklist so takeaways compare across sources.
Sales
Role takeaway
- Customer problem
- A district with a student AI ban must now approve, procure and monitor the AI it does allow under detailed rules and limited staff.
- Stakeholders
- Department of Curriculum and Instruction
- Department of Information Technology
- Supervisor of Digital Learning Experience
- Legal Services
- AI advisory group
- Special education leaders
- Discovery questions
- How many approval requests are expected this year?
- Which tools are already on the Approved Digital Tool List?
- How will the ten procurement criteria be scored?
- How will monitoring of student inputs and outputs be staffed?
- Which operational systems use predictive analytics today?
- Value hypothesis
- A documented evaluation rubric and approval workflow could make vendor reviews faster and more consistent; no source measures this.
- Potential engagement
- A short engagement to build the AI product evaluation rubric, vendor documentation checklist and approval workflow against Regulation 124-01.
- Unsupported claims
- No evidence the ban or regulation improves learning or integrity.
- No usage or approval data.
- No cost or time-savings figures.
Pre-sales engineering
Role takeaway
- Fit
- Fits AI tools that support single sign-on, network-gated access, logging and district-controlled data terms.
- Architecture and integration
- Gate approved AI behind FCPS sign-in, roster by course and purpose, export prompt and output logs for monitoring, and flag AI products on the approved tool list.
- Prerequisites
- Approved Digital Tool List process (Regulation 500-08)
- Identity provider and rostering
- Executed data-sharing agreements
- Logging and retention plan
- Constraints
- Student use only for approved purposes
- No AI grading of learning tasks outside approved platforms
- No vendor training on district data without contract terms
- Maryland and federal student privacy law
- Security
- Block PII entry without agreements, retain monitored logs, report suspected breaches, and contract for deletion and breach notification.
- Proof of value
- Vendor answers all ten evaluation criteria with documents
- Access limited to approved courses in a test roster
- Logs available for review
- Bias check documented for operational AI
Delivery
Role takeaway
- Work
- Stand up the approval, procurement, literacy, training and incident processes the regulation requires.
- Dependencies
- Curriculum office capacity
- IT monitoring capacity
- Vendor documentation
- Advisory group formation
- Ownership
- Department of Curriculum and Instruction with the Department of Information Technology.
- Skills and adoption
- Annual role-specific staff training and teacher guidance on task design that reduces AI over-reliance without detectors.
- Governance checkpoints
- Course approval list published
- Approved tool list review
- Bias evaluation before operational AI adoption
- Advisory group review
- Annual transparency communication to families
- Acceptance criteria
- Proposed: approval decisions within 15 school days
- Proposed: AI literacy delivered to all grade 2-12 students yearly
- Proposed: no integrity finding based mainly on a detector
- Proposed: annual family notice lists AI products and data retention
- Risks
- Approval backlog
- Monitoring without staff to review
- Inconsistent enforcement across schools
- Students using unapproved AI off network
Implementation considerations
Lighthouse Advisory interpretation across the operating dimensions a public-sector buyer must settle before this evidence becomes a design. Each note answers the question under its heading for this specific source.
Architecture and integration
What must connect, and where does the AI sit in the workflow?
Approved AI products are accessible only after sign-in to the FCPS secure network, managed by the IT department, with monitored inputs and outputs; approved tools are flagged on the Approved Digital Tool List. Interpretation: this implies identity-gated access, logging and an allow-list tied to the digital tool approval process.
Governance
Who approves, reviews and stays accountable for outcomes?
Board policy plus superintendent regulation; curriculum office maintains a list of courses requiring AI; curriculum and IT approve other uses; an advisory group of teachers, administrators, students, union representatives and community members monitors implementation; approval is described as an ongoing process aligned to MSDE rubrics.
Security and privacy
What data, permissions and controls need testing?
No PII into AI products without a legal basis and executed data-sharing agreement; compliance with FERPA, COPPA, PPRA and the Maryland Student Data Privacy Act; staff have no expectation of privacy in prompts; incident reporting for AI errors, unlawful content and suspected breaches; vendor contracts must cover retention, deletion and breach notification.
Accessibility and workforce
Who is affected, and what skills or accommodations follow?
Explicitly preserves AI-enhanced accessibility tools and IEP or 504 use; requires annual staff training and prohibits AI replacing legally required evaluations, services or language access.
Procurement
What should contracts, pricing and exit terms secure?
Ten evaluation criteria, vendor documentation requirements and mandatory contract terms; approval is ongoing, not one-time.
Operating model
Which teams own the service once it runs?
Curriculum and IT jointly gate student AI, with an advisory group, incident reporting and annual transparency to families.
Publication history
- 2026-10-22K–12 · Issue 464 resources
Stable resource ID: frederick-county-md-regulation-124-01-ai-student-staff-operational-use-20261022