EU AI Act readiness checklist for AWS teams
Answer each question with yes, no or not sure. Every “no” or “not sure” is a gap worth closing, or a question for your counsel.
This is a technical readiness assessment of your cloud environment. It is not legal advice and does not certify compliance. Engage qualified counsel for legal interpretation. Article numbers refer to Regulation (EU) 2024/1689.
Inventory
- Do you have a list of every AI system you build or use, including Amazon Bedrock and SageMaker endpoints, and AI features inside SaaS tools?
- For each one, do you know whether you are its provider (you build it or put your name on it) or its deployer (you use it under your authority)?
- Is there a named owner for each system, and a record of what it is used for?
Risk classification
- Have you checked every use against the prohibited practices in Art. 5, such as social scoring or emotion recognition at work?
- Have you checked every use against the high-risk areas in Annex III, such as recruitment, credit scoring or access to essential services (Art. 6)?
- Have you recorded why each system is, or is not, high-risk?
AI literacy
- Have the people who operate or rely on these systems had training proportionate to their role (Art. 4)?
Transparency
- Do users know when they are talking to a chatbot rather than a person (Art. 50)?
- Is synthetic image, audio or video content, and deepfakes in particular, marked or disclosed as AI-generated (Art. 50)?
Deployer duties for high-risk systems
- Do you use each high-risk system according to its provider's instructions for use (Art. 26)?
- Is human oversight assigned to named people with the competence and authority to intervene (Art. 26)?
- Are the logs the system generates kept for at least six months, in your own AWS accounts, with retention you can prove (Art. 26)?
- Do you inform the people affected, and workers' representatives before workplace use (Art. 26)?
- If you are a public body or provide public services, have you done a fundamental-rights impact assessment (Art. 27)?
Evidence on AWS
- Is Bedrock model invocation logging, or the equivalent for your endpoints, switched on and retained?
- Can you show which model and version served a given decision, and when it changed?
- Are CloudTrail and your application logs protected from deletion by the team that runs the system?
When the duties apply
- 2 February 2025
- Prohibited practices and AI literacy apply.
- 2 August 2025
- Obligations for general-purpose AI model providers apply.
- 2 August 2026
- Most remaining obligations apply, including transparency and the Annex III high-risk duties, unless the EU amends the timeline.
- 2 August 2027
- High-risk rules for AI in regulated products (Annex I) apply.
Too many “not sure” answers?
The AI Act deployer readiness assessment turns this checklist into evidence: an inventory, a risk-tier classification and a prioritised gap list for your AWS estate.
See the readiness packages