AI Governance Briefing — August 22, 2025
Zeph Tech is instituting rolling mitigation cycles so EU AI Act systemic-risk GPAI models continuously update Article 55 controls and share improvements with deployers.
Executive briefing: Article 55 of the EU AI Act treats systemic-risk mitigation as a continuous obligation: providers must apply state-of-the-art safeguards, monitor effectiveness, and update deployers. Zeph Tech is standing up a two-week mitigation cadence that reviews adversarial findings, tracks patch status, and issues Article 53(4) updates to customers so EU regulators can see evidence of sustained compliance beyond the August go-live.
Regulatory checkpoints
- State-of-the-art requirement. Article 55(1) compels providers to implement proportional, up-to-date mitigation measures for systemic-risk GPAI models.
- Documentation. Mitigation cycles must be recorded in the technical documentation under Article 53, including residual risks and evaluation results.
- Deployer updates. Providers must promptly communicate mitigation steps and residual issues to deployers so they can adjust downstream controls.
Control alignment
- Change management. Integrate systemic-risk patches into the enterprise change advisory board so approvals and rollback plans are captured.
- Risk dashboards. Publish metrics on mitigation velocity, outstanding risks, and customer notifications to executive risk committees.
Detection and response priorities
- Schedule weekly adversarial testing focused on newly identified attack vectors, logging severity scores and assigned mitigations.
- Monitor customer feedback and telemetry for residual harms that indicate mitigation gaps.
- Escalate overdue mitigation actions to senior engineering leadership and, if needed, regulators per Article 55(4).
Enablement moves
- Share mitigation roadmaps with key EU customers, highlighting expected timelines and residual risk coverage.
- Update investor and board reporting to reflect systemic-risk compliance status and mitigation spend.
- Coordinate with trust & safety teams so mitigation changes propagate to user policies and monitoring scripts.