EU AI Act: The Operational Playbook for Global Teams

The EU AI Act is finally here. If you operate across multiple regions the question is simple: how do we comply without pausing the roadmap? The answer is disciplined triage, clear ownership, and sensible communication with leadership.

1. Inventory What Matters

Start with systems that influence safety, fundamental rights, and commercial commitments. I split inventories into four lanes:

• High-risk candidates: Anything touching finance, employment, healthcare, critical infrastructure, or biometric monitoring.
• Limited-risk surface: Interfaces, chatbots, and explainability obligations that trigger transparency duties.
• General-purpose & foundation models: Vendors and internal builds that need downstream governance.
• Shadow AI: Spreadsheets, scripts, and pilots that slipped through the cracks.

Use a single sheet that captures purpose, jurisdictional exposure, data sources, and commercial dependencies. This becomes your truth during regulatory conversations.

2. Align People and Decisions

Three roles drive progress:

• Policy owner: Translates Act requirements into internal controls and documentation.
• Technical steward: Ensures data governance, testing, and monitoring are implemented.
• Executive sponsor: Keeps the programme resourced and aligned with strategy.

Document who signs off model risk assessments, who engages regulators, and who answers the board when timelines change.

3. Build the Minimum Viable File

You need evidence before enforcement starts. My standard dossier includes:

• Model cards outlining purpose, datasets, evaluation, and safeguards.
• Risk management protocols referencing ISO 42001, NIST AI RMF, or equivalent.
• Post-market monitoring plans with escalation playbooks.
• Procurement checklists ensuring vendors can support your obligations.

4. Communicate Upwards and Outwards

Boards want clarity on exposure, investment, and timing. Regulators want evidence that you are taking obligations seriously. Prepare a two-page summary that covers:

• Systems under high-risk scope and remediation progress.
• Dependencies on third parties and whether they are on track.
• Budget requests linked directly to legal obligations.

5. Keep it Iterative

The Act will trigger delegated acts, guidance, and enforcement trends. Set a quarterly cadence to review changes. Pair it with Lex LLM briefings that let teams query obligations on demand.

Compliance is no longer a binder on a shelf. Treat it as a living workflow that evolves with every release and regulator touchpoint.