EU AI Act readiness

    The AI Act rewards organisations that know what they run. Inventory first, classification second, paperwork last — the reverse order is how programmes stall.

    By Piotr Zenon Żabrowski · Published · Updated

    Sequence

    1. 01Inventory

      Every AI system: built, bought, and embedded in SaaS you already pay for. Include shadow usage found via egress and SaaS admin data.

    2. 02Role

      For each system decide whether you are provider, deployer, importer or distributor — obligations differ sharply.

    3. 03Risk tier

      Classify: prohibited practice, high-risk, transparency-obligation, or minimal risk.

    4. 04Obligations map

      Map tier and role to concrete obligations: risk management, data governance, logging, human oversight, technical documentation, transparency notices. ISO/IEC 42001 is a common structural reference for the risk-management and documentation parts of this step, though certification against it is voluntary and does not by itself satisfy the legal obligation.

    5. 05Evidence

      Wire the evidence into systems that already run — logs, change records, review approvals — instead of a document set that ages instantly.

    6. 06Gate

      Put an intake gate in front of new use cases so the inventory stays true.

    Timelines move; the underlying obligations mostly do not

    Dates as amended by the Digital Omnibus; the deferrals are adopted law, not a proposal
    DateWhat applies
    2 February 2025Prohibited AI practices banned (in force, unaffected by later amendments)
    2 August 2025GPAI model provider obligations and governance rules apply (in force)
    2 August 2026Original date for Annex III high-risk system obligations — superseded by the Digital Omnibus deferral below
    2 December 2027Deferred Annex III high-risk system deadline, per the Digital Omnibus adopted by Parliament (16 June 2026) and Council (29 June 2026) — now in force
    2 August 2027Original date for the remaining high-risk obligations under Annex I product-safety legislation — also deferred, see below
    2 August 2028Deferred Annex I high-risk deadline under the same Digital Omnibus text — now in force

    1Internal control set

    • Access control
    • Logging
    • Third-party risk
    • Resilience testing

    2Mapped to

    • DORA
    • NIS2
    • ISO 27001
    • GDPR
    • EU AI Act

    3Evidence source

    • Cloud config
    • Identity logs
    • Change records
    • Test reports

    4Output

    • Audit evidence pack
    • Gap register
    • Remediation plan
    AI Act obligations mapped onto an existing control set

    Frequently asked questions

    Does the AI Act replace GDPR duties?

    No. They stack. AI Act obligations sit on top of existing data-protection duties for personal data.

    Where do most companies underestimate effort?

    Vendor-embedded AI. Features arrive in tools you already own, without a decision anyone remembers making.

    What actually changed with the Digital Omnibus?

    The EU's Digital Omnibus package was adopted by the European Parliament (16 June 2026) and the Council (29 June 2026) and is now in force. It defers the Annex III high-risk system deadline from 2 August 2026 to 2 December 2027, and the Annex I product-safety high-risk deadline from 2 August 2027 to 2 August 2028. Prohibited-practice bans (in force since February 2025) and GPAI transparency duties (in force since August 2025) are untouched. The dates moved; the inventory, role determination and risk classification work does not depend on them and should proceed regardless.