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Governance, compliance and the EU AI Act

Use AI while keeping risks under control

AI governance is the set of rules, responsibilities and controls that frame how AI is used in your company. It also prepares you for compliance with the EU AI Act, the GDPR and the ISO/IEC 42001 standard.

Updated October 11, 2026

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What's at stake

Why put AI guardrails in place now

63%

of organizations hit by a data breach have no AI governance policy, or are still developing one.

Source: IBM, Cost of a Data Breach 2025

7%

of worldwide annual turnover: the EU AI Act's fine ceiling for prohibited practices (up to €35M). For an SME, the lower of the two amounts applies.

Source: European Commission, Article 99

Dec 2, 2027

new application date for the most common “high-risk” obligations (recruitment, credit…), postponed by the Digital Omnibus.

Source: White & Case

EU AI Act timeline

What already applies, and what's coming

The Digital Omnibus (Regulation (EU) 2026/1744, in force since July 27, 2026) postponed only the “high-risk” obligations. Prohibitions, AI literacy and transparency stay on schedule.

  1. Feb 2, 2025In effect

    Prohibitions and AI literacy

    Prohibited practices (Art. 5) and the obligation to develop staff AI literacy (Art. 4).

  2. Aug 2, 2025In effect

    General-purpose AI models

    Obligations for providers of general-purpose AI models.

  3. Aug 2, 2026In effect

    Transparency

    Disclose that people are interacting with AI and label generated content (Art. 50).

  4. Dec 2, 2026Upcoming

    End of grace periods

    Marking of generated content for systems already on the market.

  5. Dec 2, 2027Upcoming

    High-risk (Annex III)

    Recruitment, credit scoring, education… Postponed from August 2026.

  6. Aug 2, 2028Upcoming

    High-risk (Annex I)

    AI embedded in regulated products. Postponed from August 2027.

Status as of October 11, 2026. Sources: White & Case · Usercentrics · Cooley.

Risk levels

Four levels, classified system by system

The EU AI Act doesn't classify a company but each use of AI. A single organization can have tools in several categories: HR is often the first sensitive area.

UnacceptableProhibited

Social scoring, behavioral manipulation, real-time biometric identification in public spaces (strict exceptions).

High riskAllowed, with strict requirements

Recruitment, credit scoring, education, biometrics, medical devices.

TransparencyInform the user

Chatbots, voice assistants, AI-generated content.

MinimalNo specific obligation

Spam filters. AI literacy (Art. 4) is still expected of your teams.

Sources: RTR · DPO Consulting.

Reference frameworks

A law, a standard, best practices

Strong governance relies on several complementary frameworks: one is binding, the others structure your practices and reassure clients and partners.

Mandatory

EU AI Act

EU regulation, organized by risk level. Can apply to companies outside the EU whose AI outputs are used in the Union.

Reach outside the EU

Personal data

GDPR and CNIL

Legal basis, purpose, impact assessment, controller and processor roles for AI projects.

CNIL AI guidance sheets

Certifiable standard

ISO/IEC 42001

AI management system: responsibilities, risks, internal audit, continuous improvement. Certification by an accredited body.

Certification

Voluntary

NIST AI RMF

Four functions: govern, map, measure and manage AI risks. Not certifiable.

The NIST framework

In Tunisia

An evolving local framework, external requirements already here

  • To date, there is no Tunisian law specific to AI.
  • The 2004 personal data law remains in force; a GDPR-aligned bill is under discussion in Parliament, and its adoption is not confirmed.
  • Your European clients, funders and partners, however, may already ask you for guarantees: getting ahead protects your markets.

Sources: AllAfrica, 31/08/2026 · Business News, 27/02/2026.

Our approach

Five steps from rules to practice

A framework inspired by the NIST AI RMF, ISO/IEC 42001 and the EU AI Act. The inventory is a recommended best practice, not a general obligation under the regulation.

  1. 01

    Inventory

    List AI uses, including those teams rely on without having declared them.

  2. 02

    Classify

    Map each use to a risk level and to the personal data involved.

  3. 03

    Set guardrails

    Write the usage policy, appoint owners, define human sign-offs.

  4. 04

    Train

    Build your teams' AI literacy, tailored to each role.

  5. 05

    Monitor

    Measure, audit, improve, and prepare for ISO/IEC 42001 if it is useful to you.

General information, not legal advice. How the EU AI Act, the GDPR or Tunisian law applies depends on your situation: have your compliance decisions validated by legal counsel. Content updated October 11, 2026.

FAQ

AI governance and the EU AI Act: your questions

What is AI governance in a company?

It is the set of rules, responsibilities and controls that frame how AI is used: usage policy, risk classification, data protection, employee training and ongoing monitoring.

Does the EU AI Act apply to my Tunisian company?

The regulation also covers providers and deployers established outside the European Union when their AI outputs are used in the Union. The exact scope of this rule is not settled: legal advice is recommended for your case.

Has the EU AI Act been postponed?

Only in part. The Digital Omnibus postponed the “high-risk” obligations to December 2, 2027 (Annex III) and August 2, 2028 (Annex I). Prohibitions, AI literacy and transparency stay on schedule.

What are the penalties?

Up to €35 million or 7% of worldwide annual turnover for prohibited practices, and up to €15 million or 3% for most other obligations. For SMEs, the lower of the two amounts applies.

Do you need ISO/IEC 42001 certification?

No, the standard is voluntary. It structures AI governance and can reassure clients and partners. Certification is issued by an accredited body, not by ISO.

Where should we start?

With a baseline: which AI uses exist in your company, what data they touch and what level of risk they carry. Then simple usage rules and employee training.

Get ahead instead of catching up

A conversation to map your AI uses, identify your risks and define your first rules.