Module 02 of 09

    AI Governance & Responsible Innovation

    Your organisation is already using AI. The question is whether its leadership is governing it.

    Knowing where AI is used, who owns the risk, and what the AI Act requires.

    01. The Leadership Agenda

    Why it's on the leadership agenda

    The EU AI Act is already in force. Prohibited practices have been banned since 2 February 2025, and obligations for general-purpose AI models have applied since 2 August 2025.

    The Digital Omnibus, adopted in June 2026, delayed the high-risk deadlines but did not remove them. Standalone high-risk systems now fall due on 2 December 2027, which gives leadership teams time to prepare and no more.

    Most leadership teams cannot yet say where AI is used across the business, which uses are high-risk, or who owns the risk. That gap is where regulatory, reputational and commercial exposure sits.

    02. Scope

    What the module covers

    01

    Where AI sits in your organisation today, including tools adopted by staff without approval

    02

    Risk classification under the AI Act: prohibited, high-risk, transparency and minimal-risk uses

    03

    Provider or deployer: how your role changes your obligations

    04

    Setting an AI risk appetite the board can approve and defend

    05

    Who owns AI risk, how it is escalated, and how it reaches the board

    06

    Transparency duties for AI-generated content and customer-facing AI

    03. Leadership Questions

    What your leadership team will be able to answer

    1. Do we have a complete inventory of the AI systems we build, buy and use?

    2. Are any of them prohibited or high-risk, and are we ready for December 2027?

    3. Who in the executive team is accountable for AI risk, and how does it reach the board?

    4. Where does AI touch personal data, and how does that interact with GDPR?

    5. What have we told customers, staff and regulators about our use of AI?

    04. Regulatory Frame

    The regulatory frame

    EU AI Act (EU) 2024/1689: prohibited practices

    Certain AI uses are banned outright. The highest penalties apply here.

    Applied from 2 Feb 2025

    AI Act: general-purpose AI models

    Obligations on providers of GPAI models, and supervision by the AI Office.

    Applied from 2 Aug 2025

    AI Act: transparency (Art. 50)

    Disclosure duties for AI that interacts with people or generates content. Marking of AI-generated content has a grace period to 2 Dec 2026.

    Applied from 2 Aug 2026

    AI Act: high-risk systems, as amended by the Digital Omnibus

    Risk management, data governance, human oversight and registration for high-risk uses.

    Annex III: 2 Dec 2027; Annex I: 2 Aug 2028

    AI Act: AI literacy (Art. 4), as amended

    Providers and deployers must support AI literacy among staff.

    In force

    Dates reflect the position as of September 2026. Every engagement begins with a current regulatory review.

    05. Outcomes

    What you leave with

    A first-pass inventory of AI systems built, bought and used, with owners

    A risk classification of those uses against the AI Act categories

    A draft AI risk appetite statement for board approval

    A clear accountability line for AI risk, from executive owner to board

    A readiness plan working back from 2 December 2027