The 100-Day Mandate
Forget August. The battle for AI compliance is won or lost in Q1 2026
Executive Summary
The August 2026 deadline dominates AI Act planning conversations. It shouldn’t.
August is when classification documentation must be complete and systems registered. It is not when the work happens — it is when the work must already be finished.
The real window is Q1 2026. The first 100 days of the year will determine which organizations reach August with defensible positions and which arrive in crisis mode, compressing months of governance work into weeks.
This is not a planning quarter. It is an execution quarter. Organizations that treat January through March as preparation time will discover in April that preparation time ended in December.
Three decisions must be made. Three mistakes will derail them. And by April, the gap between organizations that executed and those that waited will be visible — and difficult to close.
The January Question
One question determines whether Q1 produces momentum or paralysis:
Who has authority to make binding classification decisions?
Not who is monitoring the regulation. Not who sits on the AI working group. Who signs the technical file. Who decides that System X is high-risk and System Y qualifies for exemption. Who can look a regulator in the eye and defend the reasoning.
Classification sits at the intersection of legal interpretation, technical architecture, and business context. No single function owns all three. Legal understands the regulation but cannot assess system architecture. Engineering understands capabilities but may not grasp regulatory triggers. Business defines intended purpose but may not recognize when that purpose crosses a classification threshold.
Without explicit authority, decisions stall in the gap between functions. Each waits for the other. Meetings produce discussion, not determination. Documentation remains unsigned.
Organizations that resolved this governance question in December will execute in January. Organizations still debating authority structures will lose weeks — weeks they cannot afford.
The first act of Q1 is not classification. It is designating who classifies.