EU AI Act Readiness: What Startups Should Prioritize First
A practical sequencing guide for early-stage companies navigating EU AI Act obligations alongside GDPR — based on hands-on implementation experience.
The EU AI Act creates overlapping obligations with GDPR that many startups underestimate. Product features using AI for content moderation, recommendations or user profiling may trigger requirements under both frameworks simultaneously.
Start with an AI inventory: document every use case, the data it processes, and the decisions it influences. Map each use case against the Act's risk tiers before investing in documentation you may not need.
Policy work comes second. Privacy Policy, DPA and Terms of Service must reflect actual data flows — not aspirational ones. Click-through DPAs and consent mechanisms should match how your product genuinely operates.
Third-party AI tools deserve the same scrutiny as first-party features. Vendor risk assessments for AI subprocessors are becoming standard due diligence, not optional extras.
Finally, invest in AI literacy across non-legal teams. The most common compliance gap isn't missing documentation — it's product and engineering teams deploying AI features without understanding the regulatory context.