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The European Commission publishes the draft delegated act on high-risk AI systems — consultation open until 30 April 2026.

Strategic tool

Executive Checklist — AI Act Compliance

The 12 strategic questions your executive committee must address before August 2026.

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01 · MappingCritical

Do we have a complete inventory of all AI systems used or developed in our organisation?

The AI Act requires a formal register of high-risk systems (Art. 49). Without prior mapping, no compliance is possible.

02 · ClassificationCritical

Have we classified each AI system according to the 5 risk levels of the AI Act?

Classification determines all applicable obligations. A classification error exposes the organisation to sanctions.

03 · GovernanceCritical

Have we designated an AI Act compliance officer (AI Compliance Officer or equivalent)?

Art. 26 requires the designation of a person responsible for human oversight. AI governance requires clear organisational ownership.

04 · GovernanceHigh

Has our executive committee been informed of AI Act obligations and sanction risks?

Penalties can reach €35M or 7% of worldwide turnover. Senior management must be involved in AI governance.

05 · ComplianceCritical

Have we conducted a gap analysis for our high-risk systems?

The gap analysis measures the gap between the current state and the 10 legal obligations (Art. 9 to 27). It is a prerequisite for any roadmap.

06 · DocumentationHigh

Do we have technical documentation for each high-risk system (Art. 11)?

Technical documentation is mandatory before placing a high-risk system on the market or putting it into service.

07 · DataHigh

Are our training data governance practices compliant with Art. 10?

Art. 10 imposes strict requirements on the quality, representativeness and documentation of training data.

08 · OversightCritical

Have we implemented human oversight mechanisms for high-impact decisions?

Art. 14 requires effective human oversight. High-impact automated decisions (credit, recruitment, health) must be validated by a human.

09 · SuppliersHigh

Have we audited our AI solution providers on their AI Act obligations?

The deployer is responsible for system compliance, even if the provider is a third party. Contracts must include AI Act clauses.

10 · TrainingMedium

Have our teams received training on the AI Act and AI governance (Art. 4)?

Art. 4 imposes a training obligation (AI literacy) for staff involved in the development or deployment of AI systems.

11 · RoadmapCritical

Do we have a budgeted roadmap to achieve compliance before August 2026?

August 2026 is the deadline for Annex III systems. Without a formalised roadmap, the risk of non-compliance is high.

12 · MonitoringMedium

Have we set up regulatory monitoring on AI Act delegated acts and harmonised standards?

The AI Act is supplemented by delegated acts and CEN/CENELEC standards currently being developed. Monitoring is essential to anticipate changes.

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