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João André Gomes Marques
João André Gomes Marques

Posted on Edited on Originally published at dev.to

EU AI Act compliance checklist for AI engineering teams

The EU AI Act deadline for high-risk AI systems is August 2, 2026. If you are building AI agents, here is what your engineering team needs to do.

I put together a practical checklist based on Articles 9-15. Full version with checkboxes on GitHub: eu-ai-act-checklist

The Articles That Matter for Engineers

Article 9 - Risk Management
You need a documented risk management system. Not a PDF that sits in a drawer - an active process that identifies risks, tests mitigations, and updates as the system evolves.

Article 10 - Data Governance
Training data needs documentation: sources, preparation methods, bias analysis. If your agent accesses external data at runtime, you need to document that too.

Article 11 - Technical Documentation
Annex IV lists everything you need to document. Architecture, algorithms, data pipelines, performance metrics, known limitations. Start writing this now, not the week before the deadline.

Article 12 - Logging (the one most teams miss)
This is where it gets technical. The law says \"tamper-evident automatic recording of events.\" That word tamper-evident means your logs need cryptographic integrity - a regular database or log file is not enough.

In practice: every agent action needs a signed record that chains to the previous one. If someone deletes a log entry, the chain breaks and you know.

Tools that help: asqav (ML-DSA-65 signed chains), AgentMint (Ed25519 receipts), Aira (hosted receipts).

Article 13 - Transparency
Users need to know they are interacting with an AI system. Document what the system can and cannot do.

Article 14 - Human Oversight
High-risk operations need human approval gates. For AI agents, this means multi-party signing or approval workflows before destructive actions.

Article 15 - Accuracy, Robustness, Cybersecurity
Test adversarial inputs. Document accuracy benchmarks. Use post-quantum crypto if your retention period exceeds 7 years.

Start Now

The full checklist with checkboxes, evidence requirements, and tool recommendations is here: github.com/jagmarques/eu-ai-act-checklist

The deadline is 16 months away. Technical documentation alone takes weeks. Start now.

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