The CISO's Guide to the EU AI Act
The European Union's AI Act is the world's first comprehensive AI law. For CISOs and AI leaders, it represents a shift from voluntary guidelines to mandatory compliance. Here is what you need to know.
Key Takeaways
- Risk-based approach: Obligations depend on the potential harm of the AI system.
- Extraterritorial scope: Applies to any provider placing AI on the EU market, regardless of location.
- Heavy penalties: Fines up to €35M or 7% of global turnover for non-compliance.
The Risk Pyramid
The Act categorizes AI systems into four levels of risk. Most enterprise GenAI applications will fall into "High Risk" or "Limited Risk" (General Purpose AI).
Unacceptable Risk (Prohibited)
Social scoring, biometric categorization, emotion recognition in workplace/schools, predictive policing.
High Risk (Strictly Regulated)
Critical infrastructure, education, employment, essential services, law enforcement. Requires conformity assessments, logging, and human oversight.
Limited Risk (Transparency)
Chatbots, emotion recognition systems, deepfakes. Users must be informed they are interacting with AI.
Minimal Risk (Unregulated)
Spam filters, AI-enabled video games. No new obligations.
General Purpose AI (GPAI)
For companies building on top of Foundation Models (like GPT-4, Claude), the Act introduces specific rules for "General Purpose AI Models".
If you are deploying a GPAI model, you must ensure:
- Technical Documentation: Detailed records of model training and capabilities.
- Copyright Compliance: Respecting EU copyright law.
- Training Data Summary: Publishing a detailed summary of content used for training.
How Railguard Helps
Railguard AI provides the technical controls and audit trails necessary for High Risk and GPAI compliance.
- Article 12 (Record Keeping): Our cryptographic receipts provide an immutable log of every AI decision.
- Article 14 (Human Oversight): Our "Human-in-the-loop" workflow allows for manual review of flagged interactions.
- Article 15 (Accuracy & Cybersecurity): Our AI Firewall protects against adversarial attacks and ensures model robustness.
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