A Step-by-Step Action Plan to Kick-Start Your EU AI Act Compliance

Introduction: Embrace Your New Compliance Mindset

The EU AI Act is reshaping how organizations approach artificial intelligence. Whether you’re developing sophisticated AI models, integrating off-the-shelf tools, or offering AI services accessible to EU citizens, it’s crucial to understand your obligations under this transformative regulation.

This step-by-step guide will help you navigate compliance with clarity. You’ll determine if you’re regulated, inventory your AI stack, classify tools by risk, clarify whether you’re a Provider or a Deployer, and thoroughly document your efforts. This approach not only ensures compliance but also sets the foundation for trustworthy, future-focused AI development and use.

Step 1: Determine If You’re Regulated Under the EU AI Act

Start by confirming whether the EU AI Act applies to your organization. Its scope is broad, extending well beyond EU borders.

You’re Regulated If You:

• Build AI in the EU: Your AI development processes occur within the EU.

• Bring AI into the EU: You import or deploy AI from outside the EU for EU users.

• Have EU Users Interacting With Your AI: Even if you’re elsewhere, if EU citizens use your AI, you’re subject to compliance.

Why This Matters:

Knowing your regulatory status at the outset ensures you allocate compliance resources efficiently and effectively.

Step 2: Map Your AI Landscape

Next, list every AI tool and model your organization uses. Treat this as a foundational inventory that guides all subsequent steps.

How to Do It:

1. Create a Comprehensive Inventory: Identify each AI application, from advanced predictive models to basic chatbots.

2. Note Departments and Use Cases: Understanding who uses each tool and why provides context for compliance decisions.

3. Flag EU Interactions: Highlight AI systems that process EU data or have EU-based end-users.

Outcome:

You’ll have a clear map of your AI ecosystem, enabling you to prioritize compliance measures where they matter most.

Step 3: Clarify Your Role—Provider or Deployer?

Under the AI Act, your responsibilities differ depending on how you engage with AI technology.

You’re a Provider If You:

• Build AI models from scratch or heavily customize them.

• Fine-tune large language models with proprietary data.

• Create bespoke AI solutions for unique business needs.

You’re a Deployer If You:

• Use AI tools “as is,” without modifying their core functionality.

• Upload data to pre-built AI platforms without altering their underlying models.

• Rely on vendor-provided AI features with minimal customization.

Why This Matters:

Providers typically face more stringent requirements than Deployers, so knowing your role is crucial for planning your compliance activities.

Step 4: Classify Your AI by Risk Level Using a Travel Analogy

The EU AI Act takes a risk-based approach. Think of your AI systems as travelers and checkpoints they must pass through. The higher the risk, the stricter the “security” they encounter.

Risk Levels:

No-Fly Zone (Banned Practices - Act Now, Deadline Feb 2025)

• What’s Inside: AI practices that are entirely off-limits, like subliminal manipulation or exploitative tactics.

• Action: If an AI use case lands here, it’s grounded immediately. The Act doesn’t ban entire systems, just these specific harmful practices.

Airport Security Checkpoint (High-Risk AI - Get Ready, Deadline Aug 2026)

• What’s Inside: AI systems making critical decisions about people’s lives (e.g., loans, hiring, safety-critical tasks).

• Action: Apply rigorous checks—like going through thorough screenings, ID checks, and baggage scans. You need strict oversight, detailed logs, and documented safety measures.

Train Station Ticket Gate (Limited Risk)

• What’s Inside: AI tools that interact with people but aren’t life-altering (e.g., chatbots).

• Action: Like showing a ticket at a train station, these systems must announce “I’m AI!” and maintain basic records. Oversight is moderate but not as intense as the airport checkpoint.

Why This Matters:

Classifying your AI this way ensures you apply the right level of controls and oversight, focusing resources where they’re most needed.

Step 5: Document Everything—Your Compliance Lifeline

Comprehensive documentation isn’t just good practice; it’s your go-to resource if regulators come knocking. It proves your due diligence and ongoing compliance efforts.

What to Document:

1. AI Inventory and Risk Classification: Log every tool, its EU relevance, and which risk “checkpoint” it passes through.

2. Decision Records: Note key compliance-related decisions, their rationale, and who approved them.

3. System Configurations and Changes: Keep screenshots and change logs for quick reference.

Pro Tip:

Begin simply and refine over time. The goal is consistent, transparent documentation that anyone can understand and verify.

Step 6: Align Your AI Strategy with Long-Term Compliance Goals

Compliance isn’t a box to tick once and forget. It’s an evolving practice that should integrate into your organization’s strategic vision.

Next-Level Planning:

1. Regular Compliance Audits: Revisit your AI inventory, risk classifications, and documentation periodically.

2. Continuous Training: Keep teams informed about new regulations, best practices, and ethical AI principles.

3. Forward-Thinking Adoption: When introducing new AI tools, factor compliance measures in from the start.

Conclusion: From Uncertainty to Informed Action

The EU AI Act can seem complex, but by following these steps—confirming your regulatory status, mapping your AI landscape, classifying tools by risk, clarifying your role, documenting thoroughly, and planning ahead—you’ll establish a robust compliance framework.

This effort isn’t just about meeting legal requirements. It’s about building trust with users, supporting ethical innovation, and ensuring that your AI initiatives can adapt to future regulations and market opportunities. With a clear roadmap, you’re ready to move confidently into the next era of responsible AI.