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EU AI Act Deployer Obligations Explained: High-Risk AI Use, Policy Packs and Compliance Requirements

The policy pack for EU AI Act deployers is rapidly emerging as a key issue for organizations that are looking to use AI ethically, keeping in mind the European regulations. Here, we will take a deeper dive into the EU AI Act, what deployers should understand, and how organized policies assist in fulfilling legal and ethical standards.

Why the EU AI Act Matters for AI Users

The EU Artificial Intelligence Act, or simply the EU AI Act, is a significant piece of legislation established by the European Union to help with the regulation of the development, marketing, and utilization of AI systems. It lists strict guidelines designed to safeguard safety, essential rights, and democratic principles, even as it emphasizes fostering innovation and competitiveness in AI technology.

Despite the EU AI Act being a law of the EU, its influence goes beyond the Union’s limits. This essentially means that any AI system that has outputs utilized in the EU needs to follow its standards, no matter where the organization implementing it is located.

The Act is not solely regarding the developers who create AI either. Several critical provisions listed in it also pertain to deployers, or the ones who are responsible for implementing AI systems in practical applications.

If you are new to the regulation, it may be helpful to first understand the broader structure, risk classifications, and objectives of the EU AI Act before diving into deployer-specific obligations.

What the EU AI Act Actually Is

At its foundation, the EU AI Act creates a risk-oriented structure for regulating AI. It classifies systems from possibly banned to minimal-risk, setting down varying requirements for each classification. High-risk systems like those employed in hiring, education, credit scoring, healthcare choices, and infrastructure are subject to the most stringent regulations.

To add to this, the Act also outlines essential roles and responsibilities, not only for AI providers and deployers but also for other stakeholders involved in the AI systems’ lifecycle. 

Who Is a Deployer Under the EU AI Act

Under Article 3 of the EU AI Act, a deployer is defined as:

“a natural or legal person, public authority, agency or other body using an AI system under its authority, except where the AI system is used in the course of a personal non-professional activity.” 

In simpler terms, this mainly refers to the individual or entity that utilizes the AI. This can include, but is not limited to:

  • Companies that are utilizing an AI application in human resources,
  • Medical centers that are employing diagnostic artificial intelligence,
  • Government agencies that are employing AI to oversee services.

It is also important to understand that this definition does not include informal personal use, such as someone utilizing an AI application on their phone for individual tasks. 

How Deployer Obligations Are Triggered

The EU AI Act basically gives the responsibilities to deployers when AI systems are classified as high-risk. High-risk systems are identified in Annex III of the EU AI Act and consist of several AI applications that impact individuals’ lives or rights.

When a deployer wants to use a high-risk system, the law expects them to:

  • Utilize it as directed and as specified by the supplier.
  • Observe its performance over time.
  • Make certain that human supervision is established.
  • Perform assessments of fundamental rights impacts as necessary.
  • Notify about significant occurrences related to the AI. 

The main aim is not to obstruct innovation, but to guarantee that AI systems are secure, clear, and uphold fundamental rights such as non-discrimination and privacy.

Distinguishing Providers and Deployers

It’s very important to know the difference between a provider and a deployer, since their responsibilities under the EU AI Act vary to quite an extent. 

  • Provider: A provider is essentially the organization that creates or markets an AI system under its own brand. 
  • Deployer: A deployer, on the other hand, is the organization that utilizes the AI system in its activities. 

However, in certain instances, an entity can be both. For example, think of an entity that creates an AI system and subsequently employs it internally. In certain situations, a deployer that significantly alters an AI system or labels it as their own might also be regarded as a provider under Article 25 of the EU AI Act. 

This difference is quite significant as the compliance obligations for providers are more extensive, including design and market readiness, whereas deployers concentrate on safe and legal usage.

What Is the EU AI Act Deployer Policy Pack

Though the EU AI Act deployer policy pack is not defined legally in the law, it does serve as a useful concept for compliance teams. It consists of a set of internal policies, procedures, and governance measures that assist deployers in fulfilling their regulatory responsibilities under the Act.

So what exactly is the purpose of a policy pack? Here are certain things you can keep in mind to help understand this better. 

  • AI regulations usually require recorded procedures, not merely good intentions.
  • Inspectors might evaluate adherence during audits or enforcement actions.
  • Policies enable organizations to shift from reactive measures to organized governance.

These policies are fundamental to responsible AI implementation and are crucial for those deploying high-risk AI systems.

Essential Policies All AI Deployers Need

Deployers play a huge role in the use of AI, especially where ethical concerns arise. Here is a look at some of the most essential governance components that facilitate legal adherence and the ethical application of AI:

  • Implementation and Utilization Regulations

These basically specify how AI systems can be utilized in an organization. They include limitations, authorization procedures, and role designations when it comes to AI implementation. Organizations should guarantee that AI systems are utilized solely for their intended objectives.

  • Human Supervision and Responsibility

Such policies guarantee that accountable individuals oversee AI activities. This is especially crucial to avoid choices that are unsafe, biased, or otherwise damaging.

  • Data Quality and Governance for Input

Such guidelines and policies discuss how the data utilized in AI systems is verified for precision, significance, and equity. These mainly exist because Inadequate data is a frequent reason for biased or unsafe results in AI.

  • Logging, Tracking, and Record Keeping

These policies talk about having up-to-date documentation that indicates how an AI system was utilized and observed. They are crucial during audits, incident investigations, or compliance assessments.

  • Incident Identification and Advancement

Such guidelines and policies help describe how to identify issues like wrong choices or negative results, and how these are reported to the appropriate teams.

  • Clarity and Employee Education

Explains how staff, and when applicable, clients, are notified about the use of AI and what it entails for their interactions with it

When Policies Must Be Tailored to Use Cases

It is important to understand that the use of AI varies among applications. Deployers in specific fields, such as recruitment, education, or vital infrastructure, usually need extra policies that address risks unique to their sectors. Here is a look at more such examples to help you understand when and why policies need to be tailored to use cases.

  • HR and recruitment: The sector needs to protect against biased hiring and inequitable screening.
  • Financial services: Guidelines must clarify AI choices that affect credit or insurance.
  • Medical diagnostics: Should adhere to stringent safety and transparency standards in patient care.

The EU AI Act, in this regard, specifically highlights that oversight should be aligned with the effects and circumstances of AI application

Putting Policies Into Practice

Drafting a policy is merely the initial stage. Deployers have to:

  • Designate individuals to be responsible for each policy and control.
  • Incorporate policies into standard business operations.
  • Prepare teams to ensure they comprehend and adhere to them.
  • Keep records that demonstrate compliance — not merely claim it.

Regulators will anticipate this evidence-based method during their compliance reviews.

Standards That Support Compliance

Major companies frequently adopt global standards to organize governance. Amongst this is the ISO/IEC 42001 standard. This is an international standard for Management Systems of AI (AIMS).

Here is a look at what the ISO/IEC 42001 standard comprises.

  • It establishes a structure for organized AI governance throughout the entire lifecycle.
  • The standard stresses open leadership, risk control, and ongoing enhancement.
  • It also corresponds effectively with the risk-oriented, responsible standards of the EU AI Act.

Many organizations compare ISO/IEC 42001 with the EU AI Act to understand how governance standards and legal requirements intersect.

While a certification to ISO/IEC 42001 isn’t legally necessary for complying with the EU AI Act, it can undoubtedly assist organizations in establishing strong governance that withstands regulatory examination.

Organizations like the Global AI Certification Council, or GAICC, provide training and accreditation aligned with this standard, assisting professionals and organizations in showcasing their governance skills. Professionals looking to build practical expertise in AI governance can explore structured ISO/IEC 42001 certification and training programs to strengthen compliance readiness. 

Avoiding Common Compliance Pitfalls

Numerous organizations believe that AI compliance ends with setting up some safeguards or drafting policies. However, that could not be farther from the truth. Here is a look at some of the common pitfalls that organizations need to keep in mind to steer clear of them. 

  • Policies need to be implemented uniformly across all applicable teams.
  • Documentation needs to be genuine and up-to-date, rather than merely fabricated for appearances.
  • Human oversight goes beyond merely ticking a box, and this is why it needs to be substantive and recorded.

These methods assist in preventing regulatory fines and establishing trust with users.

Preparing for Enforcement and Audits

The EU AI Act is more than just a goal since any breaches can result in substantial penalties and damage to the reputation of an organization. Some of the major things that deployers need to be ready to present proof of include:

  • Application of policy
  • Evaluating outcomes
  • Training and regulatory actions
  • Records of incident management

Remember, a well-organized policy supported by recorded practices simplifies the fulfillment of these requirements significantly.

Looking Ahead: Responsible AI as a Strategic Advantage

Adhering to the EU AI Act involves more than simply ticking a legal box. It provides an opportunity to develop AI applications that are secure, clear, and reliable. The EU AI Act deployer policy pack is an essential resource in this initiative, as it helps with assisting organizations in transitioning from sporadic AI utilization to strong, accountable governance.

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About the Author

Dr Faiz Rasool

Director at the Global AI Certification Council (GAICC) and PM Training School

A globally certified instructor in ISO/IEC, PMI®, TOGAF®, SAFe®, and Scrum.org disciplines. With over three years’ hands-on experience in ISO/IEC 42001 AI governance, he delivers training and consulting across New Zealand, Australia, Malaysia, the Philippines, and the UAE, combining high-end credentials with practical, real-world expertise and global reach.

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