
GenAI Regulatory Compliance Guide for CTOs
White paper overview
This white paper helps CTOs identify the controls, evidence, and cross-team decisions required for their AI systems under the EU AI Act. It covers risk classification, provider and deployer duties, applicable Digital Omnibus deadlines, and a roadmap to audit readiness
Who this white paper is for:
CTOs and engineering leaders
Who build GenAI features and coordinate technical compliance controls.
SaaS, fintech, and platform companies
Whose features may need reclassifying when customers put them to Annex III uses.
Non-EU companies serving EU users
Who may fall within Article 2 scope when their AI output is used in the EU.
Why this white paper matters
The first AI Act duties are already in effect, and the evidence behind the later ones takes months to build.
Deadlines are already in force
Article 50 transparency duties have applied since 2 August 2026. Standalone Annex III high-risk systems come due on 2 December 2027, AI embedded in Annex I products on 2 August 2028.
Risk tier and role can change
Applying a ranking feature to hiring calls for a review of its risk classification under Article 6 and Annex III, and of who holds the provider and deployer roles under Article 25.
Compliance is an architecture decision
Human oversight, data governance, logging, and explainability are design decisions, not policy add-ons. The paper sets out what each control involves and the evidence it must leave.
Get a three-stage roadmap from transparency checks to audit-ready GenAI regulatory compliance
Authors
This white paper is authored by an Andersen executive with hands-on industry experience.
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