
Key Takeaways
- The August 2, 2026 Deadline Is Real.
- What Counts as High-Risk Under EU AI Act?
- The 12-Week Compliance Checklist.
- EPC Group EU AI Act Engagement.
On this page4 sections
The August 2, 2026 Deadline Is Real
The EU AI Act high-risk system requirements take effect August 2, 2026. Unlike GDPR (which gave organizations two years to prepare), AI Act enforcement on high-risk systems is happening NOW with active fines starting at €35M or 7 percent of global annual turnover (whichever is higher). Every enterprise serving EU residents — whether headquartered in EU or not — must comply.
What Counts as High-Risk Under EU AI Act?
Article 6 + Annex III define high-risk AI systems. The categories most enterprises will encounter:
- AI in employment — hiring, promotion, termination decisions (HR Copilots, AI screening tools)
- AI in education — admissions, scoring, performance evaluation
- AI in essential services — credit scoring, insurance pricing, government benefit allocation
- AI in law enforcement and justice — predictive policing, sentencing recommendations
- AI in critical infrastructure — energy grid, water systems, road safety
Microsoft 365 Copilot used for general productivity is NOT high-risk. Custom Copilot Studio agents used for hiring decisions ARE high-risk and subject to full Article 8-15 obligations.
The 12-Week Compliance Checklist
Weeks 1-2: Inventory + Classification
- Catalog every AI system deployed across the enterprise (use Microsoft Defender Agent SPM if available)
- Classify each against Annex III high-risk categories
- Document the AI literacy gap for any roles interacting with classified systems (Article 4)
Weeks 3-4: Risk Management System (Article 9)
- Establish a risk management lifecycle for high-risk systems
- Document known and reasonably foreseeable risks
- Document residual risks after mitigation
Weeks 5-6: Data Governance (Article 10)
- Document training, validation, testing dataset characteristics
- Document data quality + relevance + representativeness
- Document bias detection and mitigation
Weeks 7-8: Technical Documentation (Article 11 + Annex IV)
- General description of the AI system + intended purpose
- Detailed description of system components and development
- Information about the system's performance + accuracy
Weeks 9-10: Record-Keeping + Transparency (Articles 12 + 13)
- Automated logging of high-risk system operation
- Instructions for use for deployers
- Information on accuracy + robustness
Weeks 11-12: Human Oversight + Accuracy (Articles 14 + 15)
- Document human oversight measures
- Document accuracy + robustness + cybersecurity testing
- Final conformity assessment
EPC Group EU AI Act Engagement
EPC Group runs 12-week EU AI Act compliance engagements for Fortune 500 enterprises with high-risk AI systems. Pricing: $75K-$250K fixed-fee depending on system count and complexity. We map every requirement against Microsoft Purview Compliance Manager templates, Microsoft Defender Agent SPM inventories, and Microsoft 365 audit logs.
See: Microsoft Purview Compliance Manager AI Framework Attestation, NIST AI Risk Management Framework Enterprise Guide, AI Skill Development 2026: EU Article 4.
Schedule an EU AI Act readiness assessment at /contact.
Errin O'Connor
Founder & Chief AI Architect
Microsoft Press bestselling author with enterprise consulting experience since 1997.
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