The EU AI Act checklist: requirements, ISO 42001 alignment, and practical next steps

The EU AI Act introduces legal obligations for AI systems placed on the EU market or used in the EU. This checklist summarizes common program steps and shows where ISO 42001 can operationalize governance—but legal analysis is still required.

Related: How ISO 42001 helps with EU AI Act · Collection

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Key takeaways

• EU AI Act is law; ISO 42001 is a certifiable management system—complementary, not interchangeable.
• Classify systems by risk tier (prohibited, high-risk, GPAI, etc.) with counsel.
• Document data, monitoring, human oversight, and incident processes.
• Use ISO 42001 AIMS as the operating system for evidence and improvement.

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EU AI Act checklist (high level)

Work with legal counsel; typical program tasks include:

• Inventory AI systems and intended use in the EU
• Classify risk category per system
• Assign provider vs deployer responsibilities
• Document technical documentation and logging where required
• Establish human oversight for high-risk use cases
• Plan conformity assessment pathways where applicable
• Review third-party AI and contractual flow-down
• Train teams on prohibited practices and governance
• Integrate incidents and serious incident reporting workflows
• Map controls to internal policies and evidence store

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How ISO 42001 helps

ISO 42001 provides structured:

• Risk assessment and treatment for AI
• Roles, competence, and management review
• Annex A controls for lifecycle governance

See the dedicated alignment article: ISO 42001 and EU AI Act.

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Next steps

1. Legal classification workshop
2. Gap vs EU AI Act and ISO 42001 Annex A
3. Implement AIMS with 13-point checklist
4. Automate evidence with compliance software

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Disclaimer (legal note)

This checklist is not legal advice. EU AI Act obligations depend on role, system classification, and timelines. Consult qualified counsel.