AI Policy Template for EU-Based Companies
Built for organizations subject to EU AI Act and GDPR
EU-based companies operate under the most prescriptive AI regulation in the world. The EU AI Act imposes risk classification, conformity assessment, and transparency obligations that generic policies simply do not address. Organizations that wait for enforcement to begin will scramble; those that prepare now will have a competitive governance advantage.
Policy Needs for EU-Based Companies
- EU AI Act risk-classification assessment for every AI system in the inventory
- GDPR-compliant data processing agreements for AI vendors handling EU personal data
- Transparency obligations including disclosure of AI-generated decisions to affected individuals
- Conformity assessment procedures for high-risk AI systems as defined by the EU AI Act
- Human oversight mechanisms mandated for high-risk automated decision-making
- Record-keeping obligations aligned to EU AI Act Article 12 requirements
Key Clauses to Include
- 1AI Act Risk ClassificationRequire every AI system to be classified as minimal, limited, high, or unacceptable risk under the EU AI Act, with documented justification and annual reclassification review.
- 2Transparency and DisclosureMandate that individuals interacting with AI systems are informed they are doing so, and that AI-generated decisions include an explanation of the factors considered.
- 3High-Risk Conformity AssessmentEstablish a conformity assessment workflow for high-risk AI systems, including technical documentation, quality management, and third-party audit where required.
- 4GDPR Data Processing AlignmentRequire that all AI data processing activities are documented in the ROPA, covered by lawful basis, and subject to DPIA where automated profiling affects individuals.
- 5Human Oversight MechanismDefine human-in-the-loop or human-on-the-loop requirements for every high-risk AI system, specifying who can intervene, when, and how override decisions are logged.
What Generic Templates Miss
- Generic templates do not include EU AI Act risk-classification workflows, leaving organizations unable to demonstrate compliance with the tiered framework
- Standard policies treat GDPR and AI governance as separate concerns instead of integrating DPIA, ROPA, and AI risk assessment into a unified process
- Boilerplate frameworks omit the conformity assessment procedures that the EU AI Act requires for high-risk systems before market deployment
PolicyGuard automates EU AI Act risk classification and integrates GDPR data processing requirements into a single governance workflow. Start a free trial and get EU-compliant today.
