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AI Security & Governance

EU AI Act Readiness for providers and deployers

Know which tier each of your AI systems falls into, what that obliges you to do, and what evidence you need. We do the technical work; your counsel owns the legal call.

  • Technical readiness work
  • 2–3 week gap analysis
  • Works with your DPO or counsel
Who this is for

Anyone selling into or operating in the EU with AI in the product

The Act reaches further than many teams expect. It covers systems placed on the EU market, systems used in the EU, and systems whose output is used there. It distinguishes providers, who build, from deployers, who use. Most companies are both.

  • SaaS vendors with EU customers and an AI feature in the product.
  • Employers using AI in recruiting, performance or scheduling decisions.
  • Lenders, insurers and fintechs using models for creditworthiness or pricing.
  • Healthcare, education and public sector organisations deploying AI in listed areas.
What we are and are not

We are engineers. We classify systems, build the controls and assemble technical documentation, logging, oversight and testing evidence. We do not give legal advice and we work alongside your counsel for the legal interpretation and any notified-body process.

Risk tiers

Four tiers, and obligations scale with the tier

Prohibited practices are banned outright: for example manipulative techniques that cause harm, social scoring and certain uses of biometrics.

High-risk systems are those listed in the Act's annexes: safety components of regulated products, and uses in areas such as biometrics, critical infrastructure, education, employment, access to essential services, law enforcement, migration and justice. These carry the heavy obligations.

Limited-risk systems carry transparency duties: tell people they are interacting with AI, label synthetic content, disclose deepfakes.

Minimal-risk systems, the majority, have no new obligations beyond existing law. General-purpose models have their own, separate obligations on their providers.

EU AI Act risk tiers as a pyramid: prohibited at the top (banned), high-risk below it (risk management, documentation, oversight, conformity assessment), limited risk (transparency duties) and minimal risk at the base (no new obligations). Obligation intensity rises towards the top. General-purpose models have separate obligations. Prohibited banned practices High risk risk management · data governance · documentation human oversight · conformity assessment · logging Limited risk transparency: tell people they are interacting with AI label synthetic content and deepfakes Minimal risk no new obligations · voluntary codes of conduct most internal tooling, spam filters, recommendation tweaks obligation intensity General-purpose models: separate obligations on their providers, independent of the tiers above
Most systems sit in the bottom two tiers. Classification is the first job because it decides everything that follows.
Obligations by role

High-risk obligations for providers and for deployers

The provider carries most of the weight. The deployer's duties are about using the system as intended, keeping people in the loop and keeping records. Where you are both, you do both.

AreaProvider (builds, places on market)Deployer (uses under its authority)
Risk managementEstablish and maintain a risk management system across the lifecycleUse the system according to the provider's instructions
Data governanceTraining, validation and test data quality, relevance and bias examinationKeep input data relevant and representative, where under your control
Technical documentationProduce and maintain documentation before placing on the marketKeep the instructions for use and your own records
LoggingDesign for automatic event loggingRetain the logs the system generates for the required period
TransparencyProvide clear instructions for use, including what the system can and cannot doInform affected people, including workers, where the Act requires
Human oversightDesign so that people can understand, monitor and overrideAssign trained, competent people with authority to intervene
Accuracy, robustness, cybersecurityAchieve and demonstrate appropriate levels throughout the lifecycleMonitor operation and report serious incidents to the provider
Conformity and registrationConformity assessment, declaration, marking, registrationCertain deployers register their use; some must run a fundamental rights impact assessment
Post-marketMonitoring, corrective action, serious incident reportingInform the provider and authorities of serious incidents
AI literacyTrain staff to a sufficient level of AI literacyTrain staff to a sufficient level of AI literacy
Role creep

A deployer that puts its own name on a high-risk system, changes its intended purpose or substantially modifies it can become the provider, with the full set of provider duties. We flag this early in classification.

Phased application

The Act applies in stages

Obligations switched on in phases after the Act entered into force. The order below is what matters for planning; confirm the exact dates for your situation with counsel, as transition periods have been subject to amendment.

  1. Phase 1

    Entry into force

    The regulation became law. Nothing was yet enforceable, but the clock started for every later phase.

  2. Phase 2

    Prohibitions and AI literacy

    Banned practices and the general AI-literacy duty applied first, within months of entry into force. Review your estate for prohibited uses now if you have not.

  3. Phase 3

    General-purpose models and governance structures

    Obligations for general-purpose model providers, and the EU and national governance bodies, followed. Mostly relevant if you train or substantially fine-tune foundation models.

  4. Phase 4

    Most high-risk and transparency obligations

    The bulk of the Act, including most high-risk requirements and the transparency duties for limited-risk systems. This is the phase most product teams are preparing for.

  5. Phase 5

    High-risk AI in regulated products

    AI that is a safety component of products under existing EU product law, such as medical devices and machinery, has the longest transition.

How we work

Readiness in four moves

  1. Inventory and classify

    List every AI system, decide provider or deployer for each, assign a tier with written reasoning your counsel can review.

  2. Gap analysis

    Compare each high-risk and limited-risk system against its obligations: documentation, logging, oversight, accuracy testing, transparency.

  3. Close gaps in order

    Transparency notices and logging first because they are cheap. Then oversight design, evals and documentation. Then conformity preparation.

  4. Evidence and rhythm

    An evidence folder per system and a review trigger on model, data or purpose change. This slots into the governance cycle.

FAQ

Frequently asked questions

We are a UK company. Does the EU AI Act apply to us?

It applies if you place AI systems on the EU market, or if the output of your system is used in the EU, regardless of where you are established. Many UK vendors with EU customers are providers under the Act. Confirm your position with counsel; we handle the technical side.

Is our customer-support chatbot high-risk?

Usually not. A general support assistant is typically limited-risk, with transparency duties: users must know they are talking to AI. It becomes high-risk if it makes or materially informs decisions in listed areas such as credit, employment or access to essential services.

What is the difference between a provider and a deployer?

A provider develops an AI system or has it developed and places it on the market under its own name. A deployer uses an AI system under its own authority. If you substantially modify or rebrand a high-risk system you may become its provider. Read our compliance guide for worked examples.

Do you provide legal advice?

No. We provide the technical classification, gap analysis, controls and evidence. We work alongside your legal counsel or data protection officer, who owns the legal interpretation.

How long does readiness take?

Classification and gap analysis take two to three weeks. Closing gaps for a high-risk system can take one to two quarters depending on documentation, logging and oversight maturity. Limited-risk systems are usually a matter of weeks.

Talk to us about your AI project

Tell us what you are trying to do, which systems are involved and what is in the way. We reply within one business day with an opinion and a suggested next step.