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Inside the EU AI Act: Your Classification Tool for Navigating High-Risk Compliance Requirements

The step-by-step framework every executive needs to turn regulatory ambiguity into actionable compliance strategy

Violeta Klein, CISSP, CEFA's avatar
Violeta Klein, CISSP, CEFA
Nov 03, 2025
∙ Paid

Executive Summary

Most organizations cannot definitively answer a single, critical question: “Which of our AI systems trigger high-risk compliance requirements under the EU AI Act by August 2027?”

This ambiguity creates a dual financial trap. Misclassifying minimal-risk systems as high-risk forces organizations to incur unnecessary compliance costs—estimated at €6,000 to €7,000 in direct expenses per system - diverting essential resources toward mandatory high-risk infrastructure (risk management systems, technical documentation, governance frameworks) that the system doesn’t require. For organizations deploying dozens or hundreds of AI systems, this resource misallocation multiplies exponentially.

Underclassifying actual high-risk systems carries far more severe consequences. Organizations that fail to implement mandatory requirements such as data governance frameworks (Article 10) face penalties reaching €20 million or 4% of worldwide turnover per violation. If the underclassified system enables a prohibited AI practice, penalties escalate to €35 million or 7% of worldwide annual revenue. With a significant majority of organizations now using AI and many deploying multiple systems in production, the exposure from misclassification is existential.

With the August 2026 deadline for initial compliance and registration of high-risk systems quickly approaching, and the final enforcement of high-risk rules due by August 2027, the classification decision is no longer optional. It is your organization’s most consequential compliance decision.

This article provides the step-by-step classification framework that transforms regulatory ambiguity into strategic clarity, allowing C-level leadership to make defensible, documented determinations about which systems require high-risk compliance infrastructure and which do not.

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