The EU AI Act’s obligations for high-risk AI systems are now enforceable. The headlines have mostly framed this as a story for legal and engineering teams — but if you work in communications or marketing, some of it lands on your desk too. Here’s a practical checklist.
1. Inventory the AI you actually use
Most marketing and communications teams now use AI daily: content generation, personalization engines, audience scoring, chat assistants, translation. You can’t assess exposure until you know what’s in use. List every tool, what data flows into it, and whether its outputs reach EU customers or employees.
2. Know your role: provider or deployer
The Act assigns different obligations depending on whether you build an AI system or use one. Most communications teams are deployers — and deployers of high-risk systems must use them according to the provider’s instructions, assign human oversight, retain system logs, and notify people affected by the system’s decisions.
3. Check whether transparency rules touch your content
The Act includes transparency obligations for AI-generated and AI-manipulated content. If your team publishes synthetic media — AI-generated imagery, cloned voices, deepfake-style video — disclosure requirements apply. Build labeling into your workflow now, not after a complaint.
4. Take the AI literacy requirement seriously
Article 4 of the Act requires organizations to ensure that staff working with AI systems have sufficient AI literacy. That has been in force since early 2025 — and it’s a genuinely good idea regardless of jurisdiction. A team that understands what AI can and can’t do produces better work and takes fewer risks.
5. Document as you go
The consistent thread across the Act’s obligations is evidence: risk assessments, data governance, human oversight, record-keeping. Penalties for non-compliance with high-risk obligations reach €15 million or 3% of global annual turnover. The organizations that find enforcement uneventful are the ones whose documentation already exists.
The upside
Governance done well isn’t a brake — it’s what lets you move fast with confidence. Teams that know their AI inventory, their role, and their obligations adopt new tools faster than teams that are guessing. That’s the real checklist item: turn compliance from a scramble into a capability.
Need a hand getting AI Act ready? Our AI Governance & Risk team takes organizations from exposure to evidence.
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