Iran’s tourism industry, despite possessing unparalleled capacities, faces a profound gap between its existing potential and current performance, rooted in the systematic weaknesses of the human capital cultivation system for entrepreneurship. The present study was conducted with the aim of designing and presenting a model for policy formulation in developing entrepreneurship education within Iran’s tourism industry. This research adopted a qualitative approach and utilized thematic analysis method. The participants consisted of 18 experts and key actors from three domains: public policy-making, entrepreneurship education, and tourism management, selected through purposive sampling with the technique of maximum variation. Data were collected via in-depth semi-structured interviews and analyzed using MAXQDA software through three stages of open, axial, and selective coding. The validity of the findings was ensured through participant review and data source triangulation. Data analysis led to the identification of three main themes and twelve sub-themes. The main themes include: “Integrated and Networked Institutional Governance” with sub-themes of cross-sectoral leadership and coordination, definition of roles and responsibilities of stakeholders, legal and supportive mechanisms, and sustainable resource provision; “Integrated, Context-Aware, and Ecosystem-Oriented Educational Program” with sub-themes of hybrid competencies, experiential and problem-based learning, content localization, and instructor empowerment; and “Learning System for Monitoring, Evaluation, and Continuous Improvement” with sub-themes of combined indicators of progress and impact, process evaluation, agile feedback mechanisms, and institutionalization of organizational learning. The proposed model, by integrating the three pillars of governance, education, and evaluation within a networked and dynamic structure, offers a process-oriented and indigenous framework for policy formulation in developing entrepreneurship education in Iran’s tourism industry. This model addresses simultaneous coverage of micro levels, meso levels, and macro levels, targeting the fourfold gaps in context-awareness, institutional integration, outcome evaluation, and technology integration, and can serve as a roadmap for policymakers and planners.