The promises and risks of Artificial Intelligence permeate current policy statements and have attracted much attention by AI governance research. However, most analyses focus exclusively on AI policy on the national and international level, overlooking existing federal governance structures. This is surprising because AI is connected to many policy areas, where the competences are already distributed between the national and subnational level, such as research or economic policy. Addressing this gap, this paper argues that more attention should be dedicated to subnational efforts to shape AI and asks which themes are discussed in subnational AI policy documents with a case study of Germany’s 16 states. Our qualitative analysis of 34 AI policy documents issued on the subnational level demonstrates that subnational efforts focus on knowledge transfer between research and industry actors, the commercialization of AI, different economic identities of the German states, and the incorporation of ethical principles. Because federal states play an active role in AI policy, analysing AI as a policy issue on different levels of government is necessary and will contribute to a better understanding of the developments and implementations of AI strategies in different national contexts.
