Phase 1: Discovery & Inventory (Months 1-2)
- Create a complete inventory of all AI systems in use across your organization
- Identify your role for each system: provider, deployer, importer, or distributor
- Map data flows and identify affected individuals
- Establish an AI governance steering committee
Phase 2: Risk Classification (Months 2-3)
- Classify each AI system against the Annex III high-risk categories
- Apply the Article 6 filter mechanism to confirm or exclude high-risk designation
- Check for prohibited practices under Article 5
- Identify transparency obligations under Article 50
Phase 3: Gap Analysis & Governance (Months 3-5)
- Conduct a detailed gap analysis against Articles 9-15 requirements
- Assess existing risk management, data governance, and documentation practices
- Define governance roles: CAIO, DPO coordination, CISO alignment
- Develop an AI literacy training plan under Article 4
Phase 4: Implementation (Months 5-10)
- Implement risk management systems and monitoring tools
- Create technical documentation meeting Article 11 requirements
- Set up logging and record-keeping infrastructure (Article 12)
- Implement human oversight mechanisms (Article 14)
- Conduct Fundamental Rights Impact Assessments where required
- Prepare for conformity assessment procedures
Phase 5: Ongoing Monitoring (Month 10+)
- Establish post-market monitoring systems
- Set up incident reporting procedures
- Schedule regular compliance reviews and audits
- Monitor regulatory updates and standards developments
Common Mistakes to Avoid
- Assuming the AI Act only applies to "robots" — it covers all AI systems including algorithms and ML models
- Neglecting to classify AI tools provided by third-party vendors
- Treating AI Act compliance as a one-time project rather than an ongoing program
- Failing to align AI Act compliance with existing GDPR frameworks
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