Compliance guide

    EU AI Act: a practical compliance guide

    The European AI Act is already in force and its obligations land in phases through 2028. This guide covers what applies to you depending on how you use AI, on which dates, what the fines are, and what you need documented before anyone asks for it.

    Updated: 7 October 2026 · timeline revised following the AI Omnibus

    What the EU AI Act is and who it applies to

    Regulation (EU) 2024/1689 is the world's first comprehensive law on artificial intelligence. It does not regulate the technology in the abstract: it regulates uses. Every AI system is classified by the risk it poses to people's rights, with obligations proportional to that risk.

    It applies to providers placing AI systems on the EU market and to organisations deploying them in their operations, whether or not they are established in the EU, as long as the output is used within the Union. In practice: if your team uses an LLM to process European customer data, it affects you, even when the model belongs to someone else.

    Key dates

    Updated European Commission timeline: the AI Omnibus entered into force on 27 July 2026. The delay concerns high-risk rules; it does not suspend GDPR or all other AI Act obligations.

    1. 1 August 2024

      Entry into force

      The Regulation enters into force and starts the clock on every later deadline.

    2. 2 February 2025

      Prohibited practices and AI literacy

      Uses such as social scoring and untargeted facial scraping become banned. The original AI literacy requirement was simplified by the AI Omnibus in July 2026; review the current rule and your team’s training needs.

    3. 2 August 2025

      General-purpose AI models (GPAI)

      Transparency, technical documentation and copyright-policy duties for foundation model providers. Governance rules and penalties start to apply.

    4. 2 August 2026

      General application

      General application, including transparency duties. Annex III high-risk rules are delayed until 2 December 2027 by the AI Omnibus.

    5. 2 December 2027

      Annex III high-risk systems

      High-risk rules apply to uses such as recruitment, credit scoring and education under the AI Omnibus revised timeline.

    6. 2 August 2028

      High-risk embedded in products

      Applies to AI systems that are safety components of products already covered by other Union legislation (Annex I).

    The four risk tiers

    Your first compliance task is classifying every AI system you use correctly.

    Unacceptable risk

    What it covers

    Social scoring, subliminal manipulation, emotion recognition at work or school, biometric categorisation using sensitive traits.

    What it requires

    Banned. There is no mitigation available: the use must stop.

    High risk

    What it covers

    Recruitment, credit scoring, education, essential services, justice, migration, and AI acting as a product safety component.

    What it requires

    Risk management system, data governance, technical documentation, automatic event logging, human oversight, accuracy and cybersecurity, plus registration in the EU database.

    Transparency risk

    What it covers

    Chatbots, content generators, deepfakes, systems interacting directly with people.

    What it requires

    Tell users they are interacting with an AI and label generated or manipulated content in a machine-readable way.

    Minimal risk

    What it covers

    Spam filters, video games, internal recommenders and most office use cases.

    What it requires

    No specific obligations. Voluntary codes of conduct are encouraged.

    Fines

    • Up to EUR 35 million or 7% of global annual turnover for engaging in prohibited practices.
    • Up to EUR 15 million or 3% for breaching high-risk, transparency or GPAI obligations.
    • Up to EUR 7.5 million or 1% for supplying incorrect or misleading information to authorities.

    Compliance checklist

    Ten concrete steps you can start today, ordered by what regulators ask for first.

    1

    Inventory every AI system

    Include the ones you did not buy as AI: assistants inside your CRM, code copilots, meeting transcribers. What is not inventoried cannot be governed.

    2

    Classify each system by risk tier

    Document the reasoning, not just the conclusion. Justifying why something is not high risk matters as much as the classification itself.

    3

    Establish your role in each case

    Providers and deployers carry very different duties. Fine-tuning a model on your own data can turn you into a provider.

    4

    Evidence your team's AI literacy

    Original requirement from February 2025, simplified by the AI Omnibus. Document training appropriate to your team’s roles and risks.

    5

    Set up data governance

    Which data enters each system, where it comes from, on what legal basis, and what happens to sensitive data before it reaches a model.

    6

    Log every AI interaction

    The Regulation requires automatic event traceability for high-risk systems. A record of who asked what, to which model, with which data, is your baseline evidence.

    7

    Design human oversight

    Define who can review, correct or reverse an AI-assisted decision, and show they genuinely can.

    8

    Meet user-facing transparency

    Disclose when someone is talking to an AI and label generated content. These are the easiest duties to check from the outside.

    9

    Review contracts with model providers

    Data retention, training use, processing location and sub-processors. Their failures end up being yours.

    10

    Build the evidence file

    Technical documentation, risk assessments, logs and incidents in one exportable place. Conformity is demonstrated, not declared.

    Where Privaro fits

    Privaro does not deliver compliance on its own: it covers the technical part that is hardest to improvise, which is controlling and proving what data leaves for the models.

    Detects personal and sensitive data in every prompt before it reaches the model.
    Applies policies by data type, team and provider: tokenize, mask or block.
    Logs every interaction with user, model, detected entities and the decision applied.
    Scans model responses too, catching data leaks on the way out.
    Exports audit-ready reports for your data protection officer.
    Works with OpenAI, Anthropic, Gemini and others without changing your integration.

    Frequently asked questions

    Does the EU AI Act apply if my company is outside the EU?

    Yes, if the system's output is used within the Union or you place the system on the EU market. The test is where the effect happens, not where you are headquartered.

    Does using ChatGPT at work make me an AI provider?

    Usually not: you would be a deployer, with lighter duties. But if you fine-tune the model, ship it under your own brand or substantially change its intended purpose, you can become a provider and take on the full set of obligations.

    Does the EU AI Act replace GDPR?

    No, they stack. GDPR still governs personal data processing while the AI Act adds duties about the AI system itself. One use case can breach both independently.

    What if I use streaming responses and cannot mask the output?

    With streaming, the output is audited in real time rather than masked. The detection is recorded for evidence and alerting even though the text already reached the user. Document that limitation in your risk assessment.

    This guide is informational and is not legal advice. For specific compliance decisions, consult your legal counsel.

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