AI Governance Briefing — July 18, 2025
Zeph Tech is rehearsing EU AI Act Article 55 systemic-risk scenarios so general-purpose AI models can prove mitigation readiness when obligations start in August 2025.
Executive briefing: The EU AI Act creates heightened duties for GPAI models that present systemic risk—Article 55 mandates documented risk management, adversarial testing, and swift mitigation for models whose scale or reach could amplify harm. With the twelve-month transition window ending on , Zeph Tech is running red-team exercises, safety benchmarking, and cross-market incident drills to prove its foundation models meet the Act’s “state of the art” mitigation standard.
Regulatory checkpoints
- Article 55 risk management. Providers must operate a documented risk management system that identifies, analyses, and mitigates reasonably foreseeable systemic impacts.
- Testing and evaluation. Article 55(2) requires GPAI providers to conduct adversarial and safety testing, benchmark systemic risk, and record evaluation outcomes in the technical documentation.
- Incident mitigation. Providers must implement effective mitigation and report serious incidents affecting health, safety, or fundamental rights to the European Commission and national authorities without undue delay.
Control alignment
- NIST AI RMF (Measure/Manage). Map Article 55 controls to Measure 2 evaluation pipelines and Manage 3 incident response playbooks so systemic-risk findings feed governance dashboards.
- ISO/IEC 23894:2023. Use AI risk management guidance to structure likelihood-impact scoring, control selection, and documentation for Article 55 risk registers.
Detection and response priorities
- Run adversarial tests on generative models covering disallowed content, disinformation, and biometric misuse to validate mitigation strength.
- Link evaluation failures to change-management tickets so engineering cannot promote new weights until mitigations close.
- Confirm regulator notification matrices meet Article 55 timelines and include evidence packages for cross-border incidents.
Enablement moves
- Brief executives on systemic-risk thresholds and potential designation triggers so they budget for mitigation tooling and independent assessments.
- Share evaluation summaries and mitigation plans with enterprise customers under Article 53(4) so deployers can update their own impact assessments.
- Stage a July board review of systemic-risk controls to confirm readiness for the August enforcement milestone.
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