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AI compliance

What the AI Act requires of your business

If your business uses a third-party AI assistant for ordinary tasks, it is a deployer. You do not need to obtain CE marking, register in European databases or carry out a conformity assessment. There is no general requirement for an independent audit either. Article 4 on AI literacy applies to businesses that provide or use AI systems, including small companies. The starting point is knowing which tools you use and what data they handle.

What AI compliance covers

AI compliance starts with identifying the duties that apply to each system your company uses or provides. Those duties depend on your role as a provider or deployer and on how the system is used. We use that assessment to define the work required and the evidence to keep.

The problems to solve

Sales pitches lead with fines

Audits, certifications, courses presented as mandatory, million-euro fines in the opening line. When everything sounds essential, it is hard to tell what your business actually needs.

Your company's role is unclear

Providers and deployers have different duties. Your role needs to be checked for each system: you can be the deployer of an assistant and, at the same time, the provider of a chatbot on your website.

There is no record of the tools in use

Teams may have their own subscriptions, including personal accounts, and customer data may end up in tools the company knows nothing about. Without an inventory, there is no starting point for checking which duties apply.

What we do

  • We establish your role for each system

    We check whether your company is the provider or deployer of each system. If you offer a service under your own name or change its intended purpose, we review your role and the duties that follow.

  • We record which tools are in use

    We record which tools are used, which teams use them, what they do and what data they handle. That includes tools people use without authorisation.

  • We organise the evidence

    We bring together written usage rules, the list of approved tools, records of staff guidance and notices where needed. The documentation must reflect what you actually do.

  • We review how personal data is used

    AI Act compliance does not remove your GDPR obligations. We review the legal basis, privacy notices, where data goes and whether a data protection impact assessment is needed.

What we do not do

  • We do not issue certifications

    We are neither a certification body nor a notified body, and we do not sell compliance badges. If certification is required, we tell you and point you to a body that can issue it.

  • We do not sell audits you do not need

    Ordinary use of a third-party assistant carries no general requirement for an independent audit. If that applies to you, we say so and keep the scope to the work you need.

  • We do not use fines to sell our services

    We do not use maximum fines to persuade you to buy a service. You need to know which duties apply to your business and what meeting them involves.

The work your company remains responsible for

Tools change, people move into different roles and new uses emerge. Your company must keep track of what is in use and under what conditions. A new use can change your role from deployer to provider without anyone noticing.

Keeping the tool inventory up to date

Add each new subscription and remove tools you no longer use. The inventory must reflect what people actually use: your rules and checks depend on it.

Making sure new users know how to use the tools

Anyone starting to use AI on your company's behalf needs to know which tools they may use, what data they must not enter and why answers always need checking. This guidance is part of the AI literacy measures required by Article 4, which applies to businesses that provide or use AI systems.

Reviewing your role and duties when uses change

When an internal assistant becomes a service for customers, your role and duties need to be reviewed. Make that check when you decide to change its use, before the service goes live.

The questions to start with

  • How many AI systems are in use in your company, including those accessed through personal subscriptions?

  • For each system, is your company the provider or the deployer?

  • Which of these systems process personal data about customers, staff or suppliers?

  • Do the people using them know what data they must not enter and why answers need checking?

  • If asked, could you show what you did and when?

Facts and sources

Article 4 of the AI Act applies to providers and deployers alike: both must take measures to support the development of AI literacy among their staff and anyone operating AI on their behalf. It has applied since 2 February 2025, together with the general provisions and the prohibited practices.

Commissione europea — AI Act, articolo 4consulted on 2026-09-20

The European Commission clarifies that the AI literacy duty does not require a specific level of competence to be guaranteed for each individual. There is no mandatory course, minimum number of hours or officer to appoint. What matters is that measures are proportionate to the risk and to how the systems are used.

Commissione europea — AI Literacy, domande e risposteconsulted on 2026-09-20

The rules on high-risk systems in Annex III, including biometrics, critical infrastructure, education, employment, essential services and justice, apply from 2 December 2027. Until then, these duties do not apply to those systems, despite being presented as already in force in many commercial offers.

Commissione europea — calendario di attuazione dell'AI Actconsulted on 2026-09-20

For high-risk systems covered by points 2 to 8 of Annex III, the conformity assessment is based on internal control and does not involve a notified body (Article 43). This is the provider's duty, not the deployer's.

Commissione europea — AI Act, articolo 43consulted on 2026-09-20

In Italy, Law No. 132 of 23 September 2025 has been in force since 10 October 2025, alongside the AI Act. If you practise an intellectual profession, you must inform your clients about the AI systems they use in clear, simple and comprehensive language (Article 13).

Gazzetta Ufficiale — legge 23 settembre 2025, n. 132consulted on 2026-09-20

Questions we often hear

Does a chatbot bought from a provider need certification?

If you use it as supplied, certification is normally not your responsibility: the technical duties belong to the provider. That can change if you offer it to customers under your own name or change its intended purpose.

Do staff have to take an AI training course?

No. Article 4 requires AI literacy measures proportionate to the risk and how the tools are used, without prescribing courses or minimum hours. People using the tools need to know what mistakes the tools can make, what data they must not enter and why answers need checking.

When can a deployer become a provider?

Your role can change if you put your name or brand on a high-risk system, substantially modify it while it remains high-risk, or change the intended purpose of a system that was not high-risk so that it becomes high-risk. Check this before launching a new service.

Do some sectors have additional duties?

There can be. Banking, insurance, healthcare and the public sector have their own rules, while Italian law 132/2025 adds provisions on employment and the professions. We check which apply to your business.

When is a data protection impact assessment needed?

It depends on the data being processed and how the system is used, not on whether it is labelled AI. The need is assessed case by case. Where an assessment is required, it must be completed before the system goes live.

What is the risk of leaving this unchecked?

The practical concern for a small business is not knowing which tools handle customer data. You may only find out when something goes wrong or a client asks for that information during a tender.

Does a small business need an AI Act audit?

There is no general requirement for an independent audit when you use a third-party assistant for ordinary tasks. We start with your tool inventory and your role for each system, then establish usage rules and the evidence to keep. If a more complex case emerges, we discuss it with you before proceeding.

Tell us which AI tools you already use

Start with a list of the tools in use and who uses them, even if it is incomplete. We review it with you to distinguish your company's duties from your providers' and identify the work required.