Law and justice
AI Compliance
The problem
The assistant fills in your AI register, with minimal risk in the risk column and claims about use for training in the data column, none of them sourced. The register goes to the EU client looking complete, but nobody checked it against the Act.
31 courses · 6 specific to this profession
A documented failure pattern
The EU AI Act: the superseded date of 2 August 2026
- What the tool doesAn internal compliance memo drafted by an AI tool in September 2026 for the compliance officer of a recruitment agency in Tirana. The agency uses an AI tool to filter CVs for its clients' vacancies in Italy.
- Where the tool goes wrongThe memo relies on the original text's date, which a later regulation has replaced.
- The verification stepOpen the latest consolidated version on EUR-Lex and read the “Amended by” list.
More: why it is easy to miss and the full check
Where the tool goes wrong, and why it is easy to miss
The plan, the budget and what the clients in Italy are told rest on a date that no longer holds. Regulation (EU) 2026/1744, published on 24 July 2026 and in force since 27 July 2026, replaced point (c) of Article 113: for Annex III systems, Sections 1 to 3 of Chapter III, which include Article 26, apply from 2 December 2027. A tool that relies on its training data or on the original text it finds online does not see the amendment, and the memo does not say which version the date came from; the same old text also hides the other changes made by the same regulation. Checking the date against the Act does not catch it, because 2 August 2026 really is the date in Article 113 of the Act as published on 12 July 2024, under the right article number.
The check that catches it
- First check whether the Act reaches you: for a deployer established outside the EU, Article 2(1)(c) covers it where the system's output is used in the Union. Note which outputs and which clients are linked to the EU.
- For every date in the memo, open the latest consolidated version of Regulation (EU) 2024/1689 on EUR-Lex and read the "Amended by" list at the top, not only the 2024 text.
- Find the article that sets the date, here Article 113, and see whether the point carries an amendment marker, for example ▼M1. If it does, read the point in the amending regulation and the date that regulation entered into force.
- Next to every date in the memo, write the version you compared it with and the day you checked, for example: "Compared with the consolidated text of 27.7.2026". Do not let the memo leave the office with dates that lack this note.
Where the failure pattern is documented: International study of AI assistants by the EBU and BBC (October 2025); Stanford and Yale study of AI legal research tools (May 2024); CCBE guide for lawyers (October 2025); judicial guidance for England and Wales (October 2025).Sources: European Broadcasting Union, 2025; arXiv, 2024; Council of Bars and Law Societies of Europe, 2025; Courts and Tribunals Judiciary, 2025.The case above is ours, written for work in Albania; the laws it names were checked against the official text.
What it looks like
The AI tool's draft memoOur CV filtering tool is a high-risk AI system under Annex III, point 4(a). Since our clients in Italy use our rankings, as a deployer we have the obligations of Article 26 of the EU AI Act, which apply from 2 August 2026 (Article 113).
Article 113, point (c), as amended by Regulation (EU) 2026/1744Chapter III, Sections 1, 2, and 3, with the exception of Article 6(5), shall apply from: (i) 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III.
Translated from the Albanian original.
Specialist courses for this profession
Compliance: Article 4 of the EU AI Act
Compliance: Your AI inventory
Compliance: The core risks
Compliance: GDPR
Compliance: Human oversight
Compliance: Documentation
What you leave with
Your AI register comes out with a source for every cell that is a conclusion: an article of the Act, a supplier term or a provision of Law 124/2024, plus who confirmed the classification and when. This is what reaches the EU client. In the course on the AI tool register you learn to build the register and update it under a protocol, so that it is ready whenever the client asks for it.
AI Compliance
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