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Preparing for the EU Artificial Intelligence Act: A Guide for CIOs and CTOs
The European Union finalized the Artificial Intelligence Act (AI Act) in 2024, marking a new era of accountability in AI development and deployment. This landmark legislation, which primarily targets companies operating within the EU, has a global reach and places stringent compliance requirements on organizations using AI. Here's a guide to help CIOs and CTOs prepare for this significant change.
Understanding and Classifying AI Systems by Risk Level
The AI Act applies a risk-based approach, with specific rules for prohibited, high-risk, and general-purpose AI (GPAI) systems. It's crucial for organizations to identify which AI systems they use or develop fall under these categories.
Ceasing Prohibited AI Practices
AI systems involving biometric categorization based on sensitive attributes, emotion recognition in workplaces, manipulative systems influencing behavior covertly, and social scoring are banned and must be discontinued both in development and use since early 2025.
Implementing Comprehensive Due Diligence and Documentation
From August 2, 2025, there are obligations for detailed documentation, transparency, technical evaluations, and risk management processes for AI systems, especially GPAI. This includes maintaining technical documentation, transparency on copyrighted training data, and evidence of risk assessment.
Preparing for Governance and Reporting Requirements
High-risk AI and GPAI systems require model evaluations, adversarial testing, incident reporting, and conformity assessments. CIOs and CTOs must establish processes and tools to support this governance.
Promoting AI Literacy
Ensure that employees involved in AI deployment and use have adequate understanding and training in AI compliance and risks, as mandated by the phased rollout starting February 2025.
Monitoring Regulatory Updates and Adopting Standards
CIOs/CTOs should track developments like the AI Service Desk by Germany’s Bundesnetzagentur and the European Commission’s Code of Practice and technical standards, which will serve as benchmarks for compliance and best practice.
Coordinating Cross-Functional Compliance Efforts
Since the AI Act influences technical, legal, and operational facets, CTOs and CIOs should work closely with legal, compliance, and risk teams to embed the required controls into IT systems and policies.
The timeline is critical: foundational bans took effect February 2, 2025; comprehensive due diligence and transparency obligations start August 2, 2025; further high-risk AI system rules come into force in 2026 and later years, with full AI system coverage by 2027 and beyond.
In summary, CIOs and CTOs must rapidly build governance frameworks, update technical compliance practices, ensure trained personnel, and maintain active regulatory monitoring to meet the AI Act’s stringent and phased compliance requirements starting August 2025.
Stay flexible with model and infrastructure choices to avoid vendor lock-in, using platforms like Camunda that integrate with any LLM or agent framework. Transparency and traceability are cornerstones of the AI Act. Human intervention should be integrated into AI decision-making processes, especially in high-risk scenarios. Implement input/output validation and prompt safeguards to prevent prompt injection and hallucination risks. Establish traceability for AI decision-making, linking outputs to specific inputs, rules, and model versions. Define fallback and escalation paths for AI services that may fail, routing tasks to alternate agents or humans when needed. Monitor and log all AI activity, including usage patterns, token consumption, confidence scores, and outcomes. Implement tools and platforms for transparent logic in the AI stack, such as decision tables (DMN) and visual process models (BPMN). AI governance is a technical and structural challenge that requires organizations to put policies into place and prove they can be enforced. AI data practices should align with GDPR, including data minimization and transparency principles. Regularly review and update governance policies to keep up with evolving regulations and technologies. The AI Act introduces a risk-based regulatory framework for AI systems. The AI Act signals a new era of accountability in AI development and deployment.
- To ensure compliance with the European Union's Artificial Intelligence Act, CTOs and CIOs may need to implement a technology solution for process orchestration that can manage the detailed documentation, transparency, technical evaluations, and risk management processes required for AI systems, particularly general-purpose AI.
- As the AI Act mandates human intervention in AI decision-making processes, especially in high-risk scenarios, organizations may benefit from integrating artificial-intelligence technology to automate repetitive tasks, while maintaining the ability for human oversight to avoid potential risks and ensure accountability in AI decision-making.