Tag Archives: EUAIAct

Ready for EU AI Act? Your framework probably isn’t. Here’s why.

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I’ll be honest—I’ve watched too many smart teams stumble here. They bolt GenAI onto legacy model risk frameworks and wonder why auditors keep finding gaps. Here’s what I’m seeing work with CDOs navigating the EU AI Act:

You need segmentation, not standardization. Traditional ML, GenAI, and agents carry fundamentally different risks. Treating them the same is like using the same playbook for three different sports.

Start with an AI Management System — ISO/IEC 42001 for structure, 42005 for impact assessments, 42006 for auditability. Map it to NIST’s GenAI Profile + COSAIS overlays. This isn’t box-checking; it’s how you govern at scale without chaos.

Then segment your controls: ML needs drift monitoring and data quality checks. GenAI needs prompt-injection defenses and hallucination tracking. Agents? Autonomy caps, tool allow-lists, human-in-the-loop gates, sandboxed execution, full action logs. Use OWASP’s LLM Top 10 — your security team already speaks that language.

On EU AI Act compliance: GPAI obligations are phasing in now. Inventory your systems, classify them (general-purpose, high-risk, other), run fundamental rights impact assessments for high-risk deployers, then choose your conformity path. Don’t wait.

Make it operational. Name control owners. Set SLAs. Track what matters—prompt-injection incidents, drift rates, task success, hallucination coverage, adoption rates, cycle-time savings. Require evidence (model cards, eval runs, logs) before promotion. Gate agent autonomy upgrades.

And frankly, treat anonymization as something you prove, combining technical (DP, SDC, k-anon) with organizational and process controls. Keep DPIA’s records updated per EDPB/ICO guidance.

If you’re piloting agents: cap autonomy first, scale second.

The teams moving fastest with focus aren’t skipping controls—they built the right ones from day one.

Which KPI tells you the most about your AI program’s health—risk metrics, performance indicators, or value creation? I’m especially curious what agent pilots are tracking beyond the basics.

EU AI Act´s General-Purpose AI Models (GPAI) Rules Are Live: How to prove Compliance next months.

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EU obligations for general-purpose AI kicked in on 2 Aug 2025. Models already on the market before 2 Aug 2024, must be fully compliant by 2 Aug 2027 – but boards won’t wait that long.

Over the past few weeks I’ve sat with product, legal, and model teams that felt “compliance-ready” … until we opened the evidence drawer. That’s where most programs stall. The good news: the playbook is clear now. GPAI Code of Practice (10 Jul 2025) gives a pragmatic path, and the Guidelines for GPAI Providers (31 Jul 2025) remove a lot of scope ambiguity. Voluntary? Yes. But it’s the fastest way to show your house is in order while standards mature.

Here’s how I’d tackle this —no drama, just discipline. First, align on who you are in the Act (provider vs. deployer). Then make one leader accountable per model and wire compliance into your release process.

My advice, Companies should:

  • Gap-assess every in-scope model against the Code. Do you have a copyright policy, a training-data summary, documented evals, and a working view of downstream disclosures? If any of those are fuzzy, you’re not ready.
  • Stand up model cards and incident logs; add release gates that block launch without evidence. Map risks to your cyber program using CSF 2.0 so Security and Audit can speak the same language.
  • Run an internal GPAI evidence audit. Publish an exec dashboard with: % of models with complete technical files and disclosures, incident MTTD/MTTR, and time-to-close regulator/customer info requests.

A quick reality check: big providers are splitting—some signalling they’ll sign the Code, others not. That’s strategy. Your advantage (especially if you’re an SME) is disciplined documentation that turns “we promise” into procurement-ready proof.

My rule of the thumb: if the CEO can’t see weekly movements on documentation completeness and incident handling, you are in pilot land – no matter how advanced the model sounds.

What would you put on a one-page dashboard to convince your CFO – and your largest EU customer – that your GPAI program in truly under control?

AI’s Black Box Nightmare: How EU IA Act Are Exposing the Dark Side of GenAI and LLM architectures

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With the EU AI Act entering into force, two of the most 𝐜𝐫𝐢𝐭𝐢𝐜𝐚𝐥 𝐫𝐞𝐪𝐮𝐢𝐫𝐞𝐦𝐞𝐧𝐭𝐬 for high-risk and general-purpose AI systems (GPAI) are 𝐄𝐱𝐩𝐥𝐚𝐢𝐧𝐚𝐛𝐢𝐥𝐢𝐭𝐲 and 𝐅𝐚𝐢𝐫𝐧𝐞𝐬𝐬. But current GenAI and LLM architectures are fundamentally at odds with these goals.
𝐀.- 𝐄𝐱𝐩𝐥𝐚𝐢𝐧𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐛𝐚𝐫𝐫𝐢𝐞𝐫𝐬:
* 𝐎𝐩𝐚𝐪𝐮𝐞 𝐀𝐫𝐜𝐡𝐢𝐭𝐞𝐜𝐭𝐮𝐫𝐞𝐬: LLMs like GPT or LLaMA operate as high-dimensional black boxes—tracing a specific output to an input is non-trivial.
* 𝐏𝐨𝐬𝐭-𝐡𝐨𝐜 𝐈𝐧𝐭𝐞𝐫𝐩𝐫𝐞𝐭𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐋𝐢𝐦𝐢𝐭𝐬: Tools like SHAP or LIME offer correlation, not causality—often falling short of legal standards.
* 𝐏𝐫𝐨𝐦𝐩𝐭 𝐒𝐞𝐧𝐬𝐢𝐭𝐢𝐯𝐢𝐭𝐲: Minor prompt tweaks yield different outputs, destabilizing reproducibility.
* 𝐄𝐦𝐞𝐫𝐠𝐞𝐧𝐭 𝐁𝐞𝐡𝐚𝐯𝐢𝐨𝐫𝐬: Unintended behaviors appear as models scale, making explanation and debugging unpredictable.
𝐁.- 𝐅𝐚𝐢𝐫𝐧𝐞𝐬𝐬 𝐁𝐚𝐫𝐫𝐢𝐞𝐫𝐬:
* 𝐓𝐫𝐚𝐢𝐧𝐢𝐧𝐠 𝐁𝐢𝐚𝐬: Models absorb societal bias from uncurated internet-scale data, amplifying discrimination risks.
* 𝐋𝐚𝐜𝐤 𝐨𝐟 𝐒𝐞𝐧𝐬𝐢𝐭𝐢𝐯𝐞 𝐀𝐭𝐭𝐫𝐢𝐛𝐮𝐭𝐞 𝐃𝐚𝐭𝐚: Limits proper disparate impact analysis and subgroup auditing.
* 𝐍𝐨 𝐆𝐫𝐨𝐮𝐧𝐝 𝐓𝐫𝐮𝐭𝐡 𝐟𝐨𝐫 𝐅𝐚𝐢𝐫𝐧𝐞𝐬𝐬: Open-ended outputs make “fairness” hard to define, let alone measure.
* 𝐁𝐢𝐚𝐬 𝐄𝐯𝐨𝐥𝐯𝐞𝐬: AI agents adapt post-deployment—biases can emerge over time, challenging longitudinal accountability.
𝐂.- 𝐂𝐫𝐨𝐬𝐬-𝐂𝐮𝐭𝐭𝐢𝐧𝐠 𝐃𝐢𝐥𝐞𝐦𝐦𝐚𝐬:
* Trade-offs exist between 𝐞𝐱𝐩𝐥𝐚𝐢𝐧𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐚𝐧𝐝 𝐟𝐚𝐢𝐫𝐧𝐞𝐬𝐬—enhancing one can reduce the other.
* No standard benchmarks = fragmented compliance pathways.
* Stochastic outputs break reproducibility and traceability.
𝐖𝐢𝐭𝐡 𝐤𝐞𝐲 𝐭𝐫𝐚𝐧𝐬𝐩𝐚𝐫𝐞𝐧𝐜𝐲 𝐫𝐞𝐪𝐮𝐢𝐫𝐞𝐦𝐞𝐧𝐭𝐬 𝐛𝐞𝐜𝐨𝐦𝐢𝐧𝐠 𝐦𝐚𝐧𝐝𝐚𝐭𝐨𝐫𝐲 𝐬𝐭𝐚𝐫𝐭𝐢𝐧𝐠 𝐢𝐧 𝐀𝐮𝐠𝐮𝐬𝐭 𝟐𝟎𝟐𝟓, we urgently need:
• New model designs with interpretability-by-default,
• Scalable bias mitigation techniques,
• Robust, standardized toolkits and benchmarks.
As we shift from research to regulation, engineering 𝐭𝐫𝐮𝐬𝐭𝐰𝐨𝐫𝐭𝐡𝐲 𝐀𝐈 isn’t just ethical—it’s mandatory.