Managing Shadow AI: Lessons from IT Leadership

Back in my days as an IT manager, we had a problem. Not the kind that shows up in a board report or triggers an incident ticket. The quiet kind. The kind that builds slowly, then hits you all at once – when it doesn’t work.
It started innocently enough. Someone in finance built a clever little MS Access database to track supplier invoices. It ended up on people’s PCs in secret, and this pseudo-application eventually became business-critical. Someone in HR wired up an Excel spreadsheet with macros that automated the monthly headcount report. A sales manager connected a workbook directly to the core CRM via ODBC and suddenly had a dashboard that my team knew nothing about, until data became corrupted – ODBC works both ways.
Brilliant, all of it. Genuinely creative problem-solving by people who cared about their work. But who maintains these applications, and who’s the owner? More importantly, what happens when the authors of that creativity leave? And what are the guardrails?
The Graveyard Nobody Talks About
Every IT leader reading this knows exactly what I’m describing. The Access database that only Dave knew how to run. The Excel macro that broke every time Microsoft pushed an update. The spreadsheet that was somehow, inexplicably, load-bearing — connected to three other spreadsheets, feeding a report that went to the CFO every Monday morning, and absolutely nobody could tell you how it actually worked.
We called it shadow IT. We wrote policies about it. We ran awareness campaigns. And still, the graveyard grew. When these pseudo-applications stopped working, it became IT’s problem. I became quite proficient in MS Access out of sheer necessity.
The pattern was always the same. A business problem exists and the official IT backlog is too slow. A capable, motivated individual solves it with the tools available to them. The solution works, so it spreads and becomes depended upon. Nobody documents it, nobody owns it, nobody maintains it. The person moves on. Everything breaks. IT picks up the pieces.
Sound familiar?
Meet the New Access Database
I’m watching the same film again. Different title, same plot.
Today, the tools aren’t Access and Excel macros. They’re AI agents, GPT wrappers, no-code automation platforms, and home-grown chatbots built on lunch breaks. And just like before, the people building them are smart, motivated, and solving real problems.
A marketing manager has built an AI agent that drafts campaign briefs from a simple prompt. A procurement analyst has wired up an automation that monitors supplier communications and flags risks. An operations team has a custom chatbot that answers internal policy questions — trained, informally, on a SharePoint folder that hasn’t been reviewed in eighteen months.
All genuinely impressive. All completely ungoverned. And here’s where it gets worse than the Access era.
Why This Time Is Different — And More Dangerous
At least with a broken macro, you knew it was broken. It threw an error. It crashed. Something visibly failed and someone raised a ticket.
AI tools don’t always do that. They degrade quietly. They produce outputs that look right but aren’t. They hallucinate with confidence. A spreadsheet formula either works or it doesn’t — an AI agent can give you a plausible, well-formatted, completely wrong answer, and nobody in the chain questions it because it sounds authoritative.
It gets worse from there. Someone can build a working AI agent in an afternoon, where the Access database took weeks — the blast radius of ungoverned AI is orders of magnitude larger. You could open an Access database and read the queries; a prompt chain, a fine-tuned model, or a retrieval-augmented agent is far harder to audit, even for the person who built it. AI tools embed themselves into daily workflows fast, and people stop doing the manual version within weeks — the dependency is real before anyone has noticed it forming. And those old Access databases rarely touched sensitive data at scale, whereas AI tools, by their nature, are often fed everything: emails, documents, customer records, all in service of making them useful.
There’s a dependency here that shadow IT never had. That Access database ran on someone’s PC and answered to nobody but itself. Today’s AI agent is usually calling out — to an LLM provider, a translation API, an enrichment service, a vector database hosted somewhere in the cloud. When one of those external APIs changes its terms, deprecates an endpoint, or simply goes down, the “little tool that just works” stops working, and nobody in the business understands why, because nobody knew it depended on an outside service in the first place. And the costs compound quietly in the same way. A marketing manager’s clever agent might be making thousands of API calls a month, each one small enough to seem free, until the bill arrives on a corporate card nobody in finance is tracking, or worse, on a personal card the business will never see. Shadow IT cost you in maintenance headaches. Shadow AI costs you in maintenance headaches plus a slow, invisible drip of external spend that nobody budgeted for and nobody owns.
The Question Every CIO Should Be Asking Right Now
Not “how do we stop people using AI tools?” — that ship has sailed, and frankly you don’t want to stop it. The energy and creativity driving this is exactly what organisations need.
The question is: What happens when the person who built this leaves? And the follow-up: do we even know what they built?
If you can’t answer both of those questions for every AI tool currently running in your organisation, you have an Access database problem. You just haven’t found the broken macro yet.
What Good Governance Actually Looks Like
I’m not advocating for bureaucracy. I’ve seen what happens when IT tries to lock everything down — people route around it and you end up with the same problem, just better hidden.
What I am advocating for is treating AI tools with the same basic discipline we eventually learned to apply to any business-critical system. Every AI tool should have a named owner — not a team, a person — someone accountable for what it does and what it produces. It needs documentation: what it does, what data it touches, what systems it connects to, what assumptions it’s making. This doesn’t need to be a forty-page spec; a one-page summary is infinitely better than nothing. There needs to be succession planning — what happens when the owner moves on, and is the knowledge transferable or does it live entirely in one person’s head. AI tools drift, so there needs to be a review cadence, even just annually, to ask whether this thing is still fit for purpose. And none of it works without visibility — you can’t govern what you can’t see, so create a simple register, and know what’s running, who built it, what it touches, and which external services and APIs it depends on and pays for.
We Learned This Lesson Once Already
The Access database era left a lot of organisations with painful, expensive clean-up jobs. Some are still doing that clean-up today. The lesson, eventually, was that empowering people to build things is good — but empowering them without any framework for sustainability is just deferred risk.
We have a window right now, before the AI equivalent of that graveyard gets too large to manage, to do this differently. The technology has changed. The human behaviour hasn’t. Governance has to be built in, not bolted on.




