  Recent AI governance research has focused heavily on the analysis of strategy
papers and ethics guidelines for AI published by national governments and
international bodies. Meanwhile, subnational institutions have also published
documents on Artificial Intelligence, yet these have been largely absent from
policy analyses. This is surprising because AI is connected to many policy
areas, such as economic or research policy, where the competences are already
distributed between the national and subnational level. To better understand
the current dynamics of AI governance, it is essential to consider the context
of policy making beyond the federal government. Although AI may be considered a
new policy field, it is created, contested and ultimately shaped within
existing political structures and dynamics. We therefore argue that more
attention should be dedicated to subnational efforts to shape AI and present
initial findings from our case study of Germany. Analyzing AI as a policy field
on different levels of government will contribute to a better understanding of
the developments and implementations of AI strategies in different national
contexts.
