
EU AI Act: what it asks, and where it lands in your management system.
A risk-tiered product law for AI. Most of what it asks is governance an organization running processes and a management system can build on; the rest is specific, and we know where it goes.
A regulation we work to · not legal advice
What it is, in business terms
The EU AI Act is the first comprehensive horizontal AI law. It sorts AI by risk: prohibited practices, high-risk systems, transparency duties for systems that interact with people or generate content, and minimal risk, where nothing is asked. It assigns duties by role. The provider has to build the system right and the deployer has to use it right, and Article 25 moves the line: a deployer that puts its own name on a high-risk system, substantially modifies it, or changes its intended purpose so that it becomes high-risk takes on the provider's duties. The Act reaches organizations outside the EU whose systems are used in the EU. Penalties reach up to 7% of global turnover for the most serious breaches.
The obligations apply in stages. Prohibited practices and the AI-literacy duty have applied since 2 February 2025; after the Digital Omnibus on AI, literacy is a duty to support staff's AI literacy, not to guarantee it. The general-purpose AI obligations have applied since 2 August 2025 and have been enforceable since 2 August 2026, alongside the Article 50 transparency duties. The high-risk obligations of Chapter III apply from 2 December 2027 for Annex III systems and from 2 August 2028 for AI in regulated products under Annex I. Those are application dates, moved by the Digital Omnibus on AI, Regulation (EU) 2026/1744, which left the requirements themselves largely as they were.
That timetable is the reason to start rather than the reason to wait. Inventory, classification, data governance, logging and oversight take longer to design and build than the runway allows, and the supervision machinery, the notified bodies and the standards are already in motion. The full timetable, the roles, and who supervises you in the DACH region and in Canada are on the map.
The first question is not a clause. It is an inventory.
Which AI systems do you run, bought or built? In which processes? In which role: provider, deployer, or both? In which tier? Nothing in the Act can be answered before that. An inventory also catches the systems that never arrived as AI: a feature switched on in a platform, a model inside a supplier's product, an assistant a team adopted on its own.
This is the first output of Process & AI Mapping: the AI systems in the connected model, each with its process, its data, its owner and a classification. Everything below starts from it.
The obligations, and where each one lands
One row per obligation family, in plain words. The article numbers are the Act's; the services are ours.
| What the Act asks | Where it sits in the connected model | Which service | What you hold at the end |
|---|---|---|---|
| AI literacy (Art. 4) | People, roles, competence | AI Competence (training) | A competence plan by role |
| Classification and role (Art. 6, Annexes I and III, Art. 25) | The AI systems in the model, their processes and their uses | Process & AI Mapping | The inventory, with tier and role per system |
| Risk management (Art. 9) | Risks and controls per process and per AI system, with the Act's risk object: health, safety, fundamental rights | Integrated AI Governance: a risk management process per AI system, designed into the management system you run, with ISO/IEC 42001 for the system, ISO/IEC 23894 for the risk process and ISO/IEC 42005 for the impact assessment. The harmonised standard for Article 9, prEN 18228, is still a draft; the duty applies regardless. | A documented risk management process per system, running through the lifecycle: risks to health, safety and fundamental rights identified and estimated, including under foreseeable misuse; measures designed where they can be enforced; tested, and reviewed against what operation shows. |
| Data and data governance (Art. 10) | Data as an element of the model: sources, quality, provenance | Integrated AI Governance: data management as its own process | Documented data governance per system |
| Technical documentation and logging (Arts. 11, 12) | Documentation and logs per system, held in the applications | Integrated AI Governance: the EN 18286 layer for providers | The technical file and the logs, per system |
| Transparency and human oversight (Arts. 13, 14) | Controls designed into the process, where a person stays in the loop | Integrated AI Governance | Oversight designed, assigned, evidenced |
| Accuracy, robustness, cybersecurity (Art. 15) | Evaluation and monitoring; the AI-specific threats of ISO/IEC 27090 in the ISMS | Integrated AI Governance; Independent Assessment & Auditing | Monitoring records; controls assessed |
| Quality management system (Art. 17) | The management system the provider runs, with the EN 18286 layer | Integrated AI Governance, for providers; the EN 18286 readiness assessment | One system, two evidence tracks |
| Deployer duties (Arts. 26, 27) | Use per the instructions, oversight by competent people, input data, monitoring, logs kept, affected persons informed; a fundamental-rights impact assessment where Art. 27 applies | Integrated AI Governance, deployer side; Independent Assessment & Auditing | The deployer controls, in the process, evidenced |
| Post-market monitoring and serious incidents (Arts. 72, 73) | Monitoring and incident handling per system | The EN 18286 layer; the incident procedure in the management system | A monitoring plan and a reporting procedure with the Act's deadlines |
| Transparency to people (Art. 50) | Disclosure and marking controls in the customer-facing processes | Integrated AI Governance | The disclosures and marks, designed and checked |
The Act names the obligations; the connected model shows where each one sits in your processes, systems and data, and the management system you run carries the evidence. That is the whole approach.
Where the effort usually goes, and where it should
The effort tends to go into reading clauses, writing policies and waiting for the harmonised standards. Each is understandable, and none of them produces evidence that a system meets a requirement.
It should go into four things. The inventory and the classification, because every other obligation is scoped by them. The controls where they can be enforced, in the systems, rather than asserted in a document. The evidence trail per system, since conformity is shown per system and not per organization. And the management system you already run, extended rather than duplicated.
On the standards: EN 18286, the harmonised standard for the Article 17 quality management system, was cited in the Official Journal on 14 October 2026. The rest, on risk management, logging, cybersecurity, bias, datasets and conformity assessment, are still drafts, expected in 2027. The obligations apply regardless of when their standards arrive.
What we don't do
Counsel reads the Act for you. We build what it describes, in the processes, the systems and the management system.
That is the provider's own, under Annex VI, or a notified body's under Annex VII where the Act requires one. We are not a notified body.
Certification bodies certify. Nothing on this page is a guarantee of conformity; conformity is the provider's to declare, on evidence we help you build.
How it connects
The AI management system the Act's governance is built in: policy, roles, risk and impact assessment, controls across the life cycle.
EN 18286The Article 17 standard for providers of high-risk AI systems, layered on the ISO/IEC 42001 or ISO 9001 system you run.
ISO/IEC 42005AI system impact assessment: the method behind the impact side of the risk work.
ISO/IEC 27001 and ISO/IEC 27090Article 15's security: the ISMS, and the threats specific to AI systems that it has to treat.
ISO 9001The chassis for providers that run a quality management system; EN 18286 is layered on it.
NIST AI RMFThe structure that maps the Act's outcomes to work, and the common frame in North America.
What we can say about our competence
The EU AI Act is a regulation the practice applies. No certification of conformity with the Act exists for an organization, and we claim none. Professional certifications on the Act, such as PECB’s Certified EU AI Governance Professional, attest a person’s competence; what we hold is on the About page, stated with its grade.
The record is enterprise architecture and controls in operational systems, and the qualifications on the About page, stated there with their grades.
The next step would be a mapping of the processes where AI runs, with each system classified. From there the obligations become a list with owners.
Start a conversation
Tell us where AI runs in your organization and whether you build it or buy it. We'll come back with a read on your role, the tiers that apply and a sensible first step.