AI Governance Briefing — February 3, 2025

Executive briefing: February 2025 marks the end of the EU AI Act’s six-month transition for Article 5 prohibited practices following the Regulation’s 2024 entry into force. National supervisory authorities can now issue penalties for systems that persist with untargeted biometric categorisation, social scoring, or emotion recognition in workplaces and schools. Zeph Tech provides the governance checklist—combining inventory reconciliations, risk assessments, and legal attestations—so leadership can certify prohibited AI systems are shut down or reclassified.

Key industry signals

Regulatory timeline. Regulation (EU) 2024/1689 Article 5 and Article 99(5) stipulate that bans on prohibited AI practices apply six months after the Act enters into force, placing enforcement in February 2025.
Supervisory coordination. The European Commission’s AI Office established an incident reporting template and cooperation procedures with national authorities in 2024, enabling rapid referrals once prohibited systems are discovered.
Sector guidance. Data protection authorities in France, Spain, and Italy issued 2024 advisories clarifying that biometric categorisation pilots in public spaces must stop when the Article 5 transition expires.

Control alignment

EU AI Act Article 9 & Article 53. Maintain risk management files and technical documentation that evidence the retirement or redesign of previously prohibited systems.
NIST AI RMF 1.0 Govern & Map functions. Update AI inventories, use-case approvals, and impact assessments to flag any workflows that relied on now-banned practices.
ISO/IEC 42001:2023 Clause 8. Embed prohibited-practice controls into the AI management system so audits capture termination steps and stakeholder communications.

Detection and response priorities

Run discovery scans across model registries, data lakes, and experimentation notebooks to identify biometric or emotion-recognition models still accessible in production tenants.
Instrument access monitoring so any attempt to reactivate prohibited models triggers alerts to legal, compliance, and AI governance teams.
Document remediation tickets, model card updates, and customer notifications as part of the corrective action log required by supervisory authorities.

Enablement moves

Issue executive briefings that list every banned use case, decommission timeline, and responsible owner, ensuring board oversight.
Train procurement and product teams on Article 5 prohibitions so no new vendor engagements introduce high-risk biometric capabilities without legal review.
Coordinate with HR and works councils to confirm employee monitoring tools comply with EU labour and fundamental rights expectations.
Extend the compliance roadmap with the GPAI transparency obligations briefing so product leaders track upcoming Article 53 documentation alongside prohibited-practice retirements.

Sources

Zeph Tech equips AI governance leaders with the regulatory evidence, incident playbooks, and training materials required to keep European operations compliant as enforcement accelerates.