Role determination
Establish whether you act as provider, deployer, importer or distributor for each system — the answer changes every obligation that follows.
EU AI Act
Classification, documentation and controls prepared before the obligations bite — with the reasoning written down and the evidence organised.
The EU AI Act applies obligations according to the role an organisation plays and the risk tier of each AI system. Practices deemed unacceptable are prohibited outright. High-risk systems require a risk management system, data governance, technical documentation, logging, transparency to deployers, human oversight, accuracy and robustness measures, and conformity assessment. Certain systems carry transparency duties towards affected people, and general-purpose AI models carry their own documentation and, above a capability threshold, systemic-risk obligations.
Establish whether you act as provider, deployer, importer or distributor for each system — the answer changes every obligation that follows.
Assess each use case against prohibited practices, high-risk annexes and transparency categories, with documented reasoning.
Build the documentation set expected for high-risk systems: purpose, data, design, testing, metrics, oversight and lifecycle.
Human oversight arrangements, instructions-for-use compliance, monitoring, logging and staff AI literacy.
Very likely yes, as a deployer. Deployer obligations include using systems according to instructions, assigning competent human oversight, monitoring operation, keeping logs where applicable and informing affected people in certain contexts. Substantially modifying or rebranding a system can also shift you into provider obligations.
The AI Act sets legal obligations; ISO/IEC 42001 provides a management system to meet them repeatably. Implementing the standard produces much of the governance, risk and documentation machinery the regulation expects, though the standard alone does not establish legal conformity.
A system-level classification and gap review, with the documentation plan that follows.