AI Governance Briefing — May 2, 2025
EU AI Act codes of practice for general-purpose AI are due today, and Zeph Tech is finalising Annex XI disclosures, systemic-risk triggers, and downstream enablement packages for Commission review.
Executive briefing: Nine months after Regulation (EU) 2024/1689 entered into force, is the deadline for GPAI providers to submit Commission-endorsed codes of practice under Article 56(5). Zeph Tech’s teams are validating Annex XI documentation—training data summaries, compute usage, copyright safeguards, and evaluation protocols—while cross-checking systemic-risk triggers that could lead to Article 55 designations. The submission package includes downstream deployment guidance so customers can satisfy Article 52 transparency and risk duties.
Regulatory checkpoints
- Code submission. Providers must attest to compliance with the approved code of practice or face direct application of Article 53 requirements, including expanded documentation and risk mitigation duties.
- Annex XI completeness. Ensure transparency summaries cover training data provenance, evaluation coverage, energy usage, and policies for watermarking or content provenance.
- Systemic-risk triggers. Providers must monitor indicators such as scale of deployment, compute intensity, and dual-use potential that could prompt systemic-risk designation and heightened oversight.
Control alignment
- Configuration management. Store submitted code commitments, evaluation artefacts, and mitigation plans in controlled repositories for future audits.
- Downstream assurance. Synchronise customer-facing documentation, service-level terms, and support processes with the commitments captured in the code of practice.
- Monitoring handoff. Establish playbooks for updating the Commission and national authorities when model changes affect the submitted Annex XI metrics.
Enablement moves
- Host customer briefings explaining the code-of-practice scope, residual risks, and escalation paths for serious incidents.
- Integrate code commitments into roadmap governance so future model iterations trigger re-validation before release.
- Coordinate with legal, policy, and commercial teams on how code obligations affect licensing, indemnity, and partnership agreements.
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