Compliance Briefing — December 9, 2023

Executive briefing: On December 9, 2023, the European Parliament and Council reached a provisional political agreement on the Artificial Intelligence Act. The deal confirms prohibited AI uses, obligations for high-risk systems, and tailored rules for general-purpose AI, including transparency and model documentation duties.

Immediate compliance priorities

• Use-case mapping. Inventory AI applications to classify them across prohibited, high-risk, limited-risk, and minimal-risk categories.
• General-purpose AI diligence. For foundation model developers and deployers, prepare technical documentation, risk management, and cybersecurity measures aligned to the negotiated rules.
• Governance and oversight. Stand up AI compliance committees responsible for conformity assessments, human oversight controls, and post-market monitoring.

Control alignment

• Risk management. Implement lifecycle risk management, data governance, and logging to satisfy Annex IV documentation requirements for high-risk systems.
• Transparency. Develop user disclosures and watermarking for AI-generated content where required under the compromise text.
• Incident response. Establish channels for reporting serious incidents and corrective actions to national supervisory authorities within mandated timelines.

Enablement moves

• Engage notified bodies early to understand conformity assessment expectations for high-risk AI deployments.
• Update vendor due diligence to assess AI Act compliance posture of third-party AI providers.
• Track delegated acts and standards development for technical specifications supporting implementation.

Sources

• Council of the EU: Provisional agreement on the AI Act
• European Parliament: Political agreement on the AI Act

Zeph Tech equips AI builders and deployers with risk classification, governance frameworks, and technical documentation to meet the EU AI Act.

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