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When AI Enters the Learning Process: Design Failures, Regulatory Risk and Guardrails for EdTech

Sara Portell • January 21, 2026
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Generative AI (GenAI) and emerging agentic systems are moving AI into the learning process itself. These systems don’t stop at delivering content. They explain, adapt, remember and guide learners through tasks. In doing so, they change where cognitive effort sits: what learners do themselves and what gets delegated to machines.

This shift unlocks significant opportunities. GenAI can provide on-demand explanations, examples and feedback at scale. It can diversify learning resources through multimodal content, support learners working in a second language and reduce friction when students get stuck, lowering barriers to engagement and persistence. For some learners, AI-mediated feedback can feel psychologically safer, encouraging experimentation (trial and error), revision and assistance without fear of judgement.

But these gains come with important risks. The same design choices that improve short-term performance, confidence, or engagement can weaken independent reasoning, distort social development or introduce hidden dependencies over time.

In educational contexts, especially those involving children and teens, we are talking about learning, safeguarding, regulatory and reputational risks. If the “Google effect” (digital amnesia) raised concerns about outsourcing memory to search engines, LLMs can be even more powerful in practice. Agentic and multi-agent systems raise the stakes further. As AI systems plan, adapt, coordinate, and act proactively, they can quietly assume roles that belong to learners or educators: framing problems, sequencing tasks, resolving disagreement, or deciding what happens next.

When these shifts are unexamined, learning can collapse into automated coordination, impacting cognitive development. This is why emerging standards and guidance, such as the Guidance for Generative AI in Education and Research created by UNESCO or the Generative AI: product safety standards by the UK Department for Education, take a risk-first approach to AI in education. As AI becomes embedded in learning, design choices increasingly carry regulatory, safeguarding and reputational consequences, alongside pedagogical ones.

Where AI Can Undermine Learning

AI introduces learning and developmental risks unless we actively mitigate them.

These risks are not uniform across learners. It is very important to consider age and developmental stage. Younger learners are more susceptible to over-trust, emotional reliance, and authority transfer, while older learners may better interrogate and contextualise AI outputs. Responsible educational AI requires age-appropriate constraints on autonomy, interaction style and use cases; one model of use won’t fit all learners.

Risk Accumulation

Hallucinations and biases

AI can produce confident but incorrect or biased explanations. These errors are often hard to detect and can introduce misconceptions, cognitive bias and amplify over-trust, undermining learner judgment, and reinforcing stereotypes and uneven representations.

Cognitive deskilling

When AI is available to generate answers, full solutions and completed tasks, learners offload cognitive work. This shows up as relying on full solutions rather than grappling with problems, and over time can weaken reasoning, problem-solving and persistence.

Psychological, emotional and social risk

AI learning systems built as conversational, companion-style or anthropomorphic can encourage emotional reliance, reduce peer interaction and undermine real-world support networks, especially problematic for children, distorting emotional and social development.

Context insensitivity

Without contextual adaptation, outputs can be inappropriate, misleading, or misaligned with learners’ educational context, privileging dominant knowledge frameworks and creating friction with local classroom practices.

Manipulative design

Patterns such as flattery, unjustified confidence, social pressure (“others have done this”), or reward-based engagement and monetisation-driven dark patterns can influence learner behaviour in ways not acceptable in learning contexts.

Data privacy

Continuous monitoring, collection of sensitive learner data, or reuse of data for commercial purposes or model training raise serious concerns, especially for children, treated as a high-risk group under data protection law.

Agentic autonomy

Agentic AI systems plan, adapt, and act over time. Memory and proactive decision-making can gradually shift agency away from learners (even when short-term task performance improves), creating dependency loops that are difficult to detect. Learners may rely increasingly on system guidance for task sequencing, decision-making, or problem framing, reducing opportunities for independent reasoning and productive struggle. In multi-agent systems, coordinated outputs or apparent consensus can further inflate epistemic authority, making AI guidance appear more reliable, discouraging critical evaluation.

Anti-Patterns in EdTech AI Design

Responsible edtech requires human-centred design and system-level accountability. The patterns below highlight design risks that product teams can address to reduce harm and improve learning outcomes.

01

Solution-by-default

AI is configured to generate full answers, code, solutions or explanations as the primary interaction. This encourages cognitive offloading, shortcuts productive struggle, and shifts the learner from sense-making to copying.

Red flag: Learners can complete tasks without attempting them.

02

Fluency instead of understanding

Performance while AI is active is used as a success signal, without testing whether learners can perform independently.

Red flag: Success metrics that only focus on task completion, speed or output quality, without measuring skill transfer.

03

AI as the primary authority

The system speaks with high confidence and human-like authority, discouraging questioning or verification. Multi-agent consensus is presented as more reliable rather than provisional.

Red flag: Learners rarely challenge or revise AI outputs.

04

Optimising for engagement

Design choices prioritise time-on-task, retention or satisfaction over learning depth. Persuasive nudges, flattery or gamified rewards do not drive understanding.

Red flag: Engagement metrics improve while independent performance stagnates or declines.

05

Opaque decisions

Learners and educators cannot tell why the system intervened, what information it used, or how confident it is. Errors, bias or hallucinations go unnoticed.

Red flag: It just gives an answer with no explanation or source transparency.

06

Agentic autonomy without boundaries

Agentic systems plan tasks, set goals or sequence learning steps without learner confirmation. Memory and adaptation replace learner agency over time.

Red flag: The system increasingly decides what happens next.

07

Confidence without competence

Learners feel more confident using AI, but are not given opportunities to test skills without support. Confidence becomes a misleading proxy for mastery (Dunning-Kruger effect).

Red flag: No AI-free checkpoints or ‘try without help’ moments.

08

Misuse treated as a user problem

Design assumes learners will use AI responsibly without constraints, scaffolds and literacy support.

Red flag: Responsibility is pushed to users rather than designed into the system.

09

Age and context-blind design

AI systems are deployed without adaptation to learner age or developmental stage, local curricula or cultural and linguistic context.

Red flag: The same interaction patterns, autonomy level and behaviour is applied across age groups or contexts.

Designing for Protection: Guardrails for EdTech AI

Learning harm is often an emergent property of design choices, interaction patterns and governance gaps. Responsible edtech requires human-centred design and system-level accountability.

Ground AI in learning science

AI must be grounded in human learning theory (e.g. constructivism, Inquiry-Based Learning, scaffolding, Zone of Proximal Development), not optimised for task completion, speed, fluency or output quality alone.

Why: Encourages cognitive engagement, reflection, verification and independent reasoning.

Design against over-reliance

Systems should enforce clear role boundaries, avoid authoritative or solution-first behaviour and prioritise scaffolding. Support should fade as competence increases, not persist indefinitely.

Why: Implement attempt-first flows, progressive disclosure and intentional support fading. Explicitly design for scaffolding modes (Aid/Complement) rather than replacement mode (Substitute) as the default.

Preserve agency

AI should support learners in questioning, verifying and revising, not accepting outputs at face value. Interfaces should make uncertainty visible and prompt reflection (“What would you check?”, “What do you keep and why?”).

Why: Treat agency as a core learning outcome, requiring justification, comparison and learner reasoning.

Ensure human oversight

AI should augment educator judgment, not bypass it. Responsible adoption requires explicit boundaries on which functions may be automated, which require human review and which should never be delegated to AI.

Why: Enable human review, override and escalation for consequential decisions.

Conduct longitudinal behavioural testing

Short-term confidence and efficiency gains can mask declining independent performance. Governance must include longitudinal monitoring of reliance, cognition, self-efficacy and differential impacts across learner groups.

Why: Track learning trajectories over time and monitor whether confidence and independence converge or diverge.

Design for transparency and explainability

Learners and educators should understand what the system is doing, why it intervened, what data it relied on and how confident it is.

Why: Expose reasoning and uncertainty through interaction design; make AI contributions visible in learner work.

Prevent inaccuracy and pedagogical misalignment

For AI-generated learning materials (videos, quizzes, Q&A), ensure outputs align with course content and instructional or academic goals.

Why: Use restricted retrieval from approved materials (e.g. RAG) and human oversight to prevent misinformation, biases and low pedagogical quality.

Do not dehumanize learning

Social interaction is a learning-relevant ingredient. Designs that remove it can reduce learning quality (e.g. lower perceived social presence).

Why: Position the AI as a tool or facilitator; actively redirect learners to teachers, peers or group discussion when social engagement is essential.

Treat AI literacy as a prerequisite

AI literacy for learners and educators is a prerequisite for responsible deployment; it cannot be expected to emerge automatically through use.

Why: Show what AI can/cannot do and why outputs are generated, with contextual explanations at moments of use rather than one-off onboarding. Offer distinct explanations and controls for learners, educators, parents and administrators, aligned with their decision-making responsibilities.

Co-creation, system evaluation and ongoing monitoring

Co-creation with learning and development experts, educators, learners and local domain experts is essential to ensure systems align with learning theory, developmental needs, cultural and linguistic contexts and the constraints of classroom and school environments.

For agentic and multi-agent systems, this includes testing how decisions are delegated, how disagreement is resolved, and whether collaboration supports learning or collapses into automated coordination. Because many risks surface only through repeated use, longitudinal monitoring must be treated as a governance requirement.


Treating educators, schools, learners and local domain experts as ongoing partners rather than end users helps surface risks early and recalibrate system behaviour.

Testing must cover the full AI learning system, including data sources and knowledge bases, retrieval and grounding mechanisms, prompts, interaction design, memory and adaptation, orchestration logic, and, where applicable, the dynamics of multi-agent interactions.

AI is shaping how we think, collaborate and develop over time.

Whether this strengthens or erodes learning is a design and governance choice, shared by builders and education systems. Getting this right requires clear governance, boundaries, age-appropriate safeguards, and sustained attention to how learning unfolds in practice.

Unomundi children's edtech app screenshot
Case Study

Responsible AI in child-focused edtech: lessons from Unomundi

A working example of how these guardrails play out in practice: building trustworthy AI for children through developmental psychology, human–AI interaction, and ethical governance.

Read the Case Study

How We Work With EdTech Teams

We support teams across three areas:

01

AI evaluations & behavioural risk assessments

We assess how learners and educators interact with your system: output quality, model and behaviour drift over time, and where over-reliance, authority transfer, misuse or unintended behaviours emerge.

02

Design refinement

We translate learning science and behavioural evidence into concrete design guidance (interaction patterns, autonomy boundaries, scaffolding strategies, safeguards and monitoring) that reduce risk and are developmentally appropriate while improving product value.

03

Regulatory alignment

We help teams align design and governance decisions with emerging standards and regulations before these become compliance or procurement blockers.

If you’re building or deploying AI in an education setting or for educational purposes, we’re happy to talk.

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Sara Portell, HCRAI Founder
Author
Sara Portell
Behavioural Scientist & Responsible AI Advisor
Founder, HCRAI