Overall, the data from our survey respondents highlights the multifaceted challenges and significant impacts of the EU AI Act on organisations.
From data privacy and AI governance to risk management and compliance, the findings underscore the need for comprehensive strategies to navigate the regulatory landscape. As organisations strive to implement AI effectively, addressing these key areas will be crucial for ensuring compliance, fostering innovation, and maintaining competitive advantage.
As we move forward, it is essential to focus on several key considerations and actionable next steps to successfully implement AI within the regulatory frameworks of the EU AI Act. The following list outlines critical areas that organisations should prioritize to ensure compliance, optimize resource allocation, and leverage AI technologies effectively:
PRODUCTIVITY TOOL VS COMPETITIVE ADVANTAGE
- While most organisations are investing heavily in AI, there seems to be a lack of understanding of how AI can best be implemented, i.e., its potential use cases.
- Al continues to be used predominantly as a productivity tool to reduce manual tasks of employees but has not yet been leveraged to its full extent to create new products or ways of operating. Improved AI literacy is key to unlocking the potential benefits of AI tools and systems.
AI ACTOR CLASSIFICATION
- Many do not know how they should be classified or may have incorrectly classified their organisation. Have you accurately identified what type of AI Actor you are?
- Could you be classified as a 'subsequent deployer'?
AI SYSTEM CLASSIFICATION
- How have you categorised each Al tool or system?
- Do you have a plan in place to ensure compliance with the obligations that are attached to each of the systems you provide/deploy?
TIMELINES
- AI Literacy and Prohibited AI obligations have been in place since February 2025
- General Purpose AI rules will come into effect from August 2025
- High-Risk AI rules will come into effect from August 2026
- Remaining AI Act provisions in place from August 2027
FINES & ENFORCEMENT
- Non-compliance with requirements can lead to fines of up to €15 million or 3% of worldwide annual turnover, whichever is higher.
- What are your responsibilities as an AI deployer? What do you need from your AI providers?
ETHICS & RISK
- How are you identifying ethical and operational risks?
- Are you in compliance with relevant AI Codes of Practice and Conduct?
NEXT STEPS
- Build on steps taken to comply with DORA, Operations Resilience and Outsourcing requirements.
- Enhance existing governance and internal control arrangements.
How we can help
PROGRAMME DESIGN
Leverage our specialist legal, governance, and risk expertise in the design & delivery of your implementation programme. Our pragmatic and proportionate approach will help you find a solution which fits the nature, scale, and complexity of your operations.
GAP ANALYSIS
Arthur Cox will conduct a detailed gap analysis of your existing controls, processes, and policy documents to help you identify and prioritise any:
- Legal or regulatory compliance gaps
- Process inefficiencies
- Useful best practices
PROGRAMME SUPPORT
Arthur Cox is on hand to provide support and guidance throughout your implementation project.
The combined experience of our legal experts and industry practitioners ensures that we can provide both technical and practical advice across your three lines of defence.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
