Implementation Roadmap for Companies
The EU AI Act is complex — but with a structured 7-step plan, you can systematically implement the requirements. This roadmap is applicable to companies of all sizes.
The 7-Step Plan
Step 1: Create an AI Inventory (Immediately)
Goal: Complete overview of all AI systems in the company
Record for each system:
- Name and provider
- Purpose and department
- Type of data processed
- Your company's role (provider or deployer?)
- Current documentation status
Tool: A simple spreadsheet is sufficient to start — no expensive tool needed.
Step 2: Perform Risk Classification (Month 1–2)
Goal: Assign each AI system to a risk level
Check for each system:
- Does it fall under a prohibited use case?
- Is it listed in Annex III of the AI Act (High Risk)?
- Does it directly interact with users (Limited Risk)?
- None of the above (Minimal Risk)?
Step 3: Define Responsibilities (Month 1–2)
Goal: Clear accountability for AI compliance
| Role | Responsibility |
|---|
| AI Compliance Officer | Overall responsibility, contact for authorities |
| Department Heads | Compliance of AI systems in their area |
| IT/Engineering | Technical implementation (logging, documentation, security) |
| Data Protection Officer | Coordination GDPR ↔ AI Act |
| Legal Department | Contractual aspects, liability questions |
Step 4: Conduct Gap Analysis (Month 2–3)
Goal: Where are you today vs. where do you need to be?
For each High-Risk system check:
- ☐ Risk management system in place?
- ☐ Data governance documented?
- ☐ Technical documentation created?
- ☐ Logging implemented?
- ☐ Human oversight ensured?
- ☐ Accuracy metrics defined and measured?
Step 5: Prioritize and Implement Measures (Month 3–6)
Goal: Systematically close gaps
Prioritize by:
- Compliance risk: What carries the highest penalties?
- Feasibility: What can be done quickly?
- Business impact: What affects the most users?
Step 6: Conduct Training (Month 4–6)
Goal: Sensitize all relevant employees
- Executives: AI Act overview, strategic implications
- Product teams: Technical requirements, documentation obligations
- HR/Recruiting: Specific obligations for AI in human resources
- Customer service: Transparency obligations for chatbot deployment
Step 7: Continuous Monitoring (Ongoing)
Goal: Ensure compliance permanently
- Quarterly reviews of AI systems
- Update documentation on changes
- Monitor new implementing acts and guidelines
- Annual audit by internal or external auditors
Practical Tip: Start small, but start now. Companies that begin in July 2026 won't make the deadline. Use the time.