Practical guide · AI governance and product teams
EU AI Act readiness checklist
The EU AI Act does not assign the same duties to every AI system. Start with the actual system and intended use, then have a qualified reviewer confirm the role, classification, applicable provisions, and dates. This checklist is an operational starting point, not a legal determination.
1. Inventory each system and use
Record intended purpose, users, affected people, geography, model supplier, and whether your organization provides or deploys the system in the relevant context. Recheck classification when the intended purpose or use changes.
Working record: A system register with purpose, role candidates, owner, and version.
2. Screen the legal category
Check the Act’s prohibited-practice rules, high-risk routes, and transparency provisions against the real use case. Capture the article or annex supporting each provisional decision. Do not infer that a product is high risk merely because it uses a general-purpose model.
Working record: A preliminary classification record with citations, assumptions, and counsel review status.
3. Map duties and application dates
Build a requirement list only after the role and category are reviewed. Record which entity owns each duty and check the Commission’s current implementation timeline; provisions apply on different dates. Keep the legal source beside each task.
Working record: An obligation register with source, applicability rationale, owner, and due date.
4. Attach evidence, not assertions
For applicable duties, link policies, technical documentation, instructions, logs, testing, human oversight procedures, or transparency notices as appropriate. Record the evidence version and reviewer. Missing evidence should create a task, not a green status.
Working record: An evidence index and open-action list for each system.
5. Set a review trigger
Revisit the screen when product scope, users, suppliers, law, or official guidance changes. Keep prior decisions so a reviewer can see why an assessment changed. Escalate contested classifications to qualified counsel.
Working record: A named owner, review date, and change history.