01 - Train & Adopt / EU AI Act Technical Compliance

EU AI Act Technical Compliance

The engineering half of AI Act compliance: 23Minds inventories and classifies your AI systems, writes the technical documentation, produces the testing evidence and turns logging, traceability and human oversight into architecture your team actually runs.

Entry packageEU AI Act Gap Analysisfrom EUR 5,6001 AI system · up to 4 weeks from scopingWhat is included
In short
01

Know which obligations apply

Risk classification of the system decides what the Act asks of you; the analysis names it.

02

Gaps as a 30-60-90 plan

Every gap against the technical requirements comes with an action and a date.

03

Evidence, not assurances

Inventory, documentation and test evidence in the form an auditor can read.

23Minds delivers the technical side of EU AI Act compliance for organizations that build, buy or deploy AI systems.

Show the full summary

The service inventories every AI system in use, classifies each one against the Act's risk tiers, writes the technical documentation the current obligations require, and produces adversarial-testing evidence that stands up to an audit. Logging, traceability and human oversight count as architectural requirements with named owners and working implementations, not as promises in a policy document. The engagement ends with a gap analysis and a costed remediation roadmap, plus an AI literacy plan that feeds directly into training for the people who operate these systems. Engineers, not lawyers, do this work: the team builds the technical evidence and works alongside your legal counsel or a partner law firm, which owns the legal interpretation and sign-off.

Why 23Minds

What makes this service defensible.

  • Technical scope, stated plainly

    Documentation, logging, human oversight and testing evidence; legal opinion is out of scope and named as such.

  • Price set before work starts

    Classification, inventory, gap analysis and action map; the price is fixed once the scope is agreed, four weeks.

  • Polish-first

    Written for organizations answering to Polish and EU regulators, in Polish first.

  • Eligible for BUR / KFS co-funding

    Consulting services qualify under operator rules in Poland.

How we work

The process, phase by phase.

  1. 1

    1. Inventory and discovery

    Find every AI system in use: built, bought and embedded in third-party tools. Capture purpose, users, data, model, vendor and owner for each.

    Week 1-2
    Three shelves of small boxes, some filled in and one carrying a yellow tag: every AI system in use found and labelled, whether built, bought or embedded.
  2. 2

    2. Risk classification

    Classify each system against the Act's risk tiers and your role for it, provider or deployer. Document the reasoning so legal counsel can confirm or challenge it.

    Week 2-3
    Four trays stacked with small boxes sorted into them, the top tray outlined in yellow: each system placed in its risk tier under the Act, with the company's role for it noted.
  3. 3

    3. Gap analysis

    Compare current state against the obligations that apply: documentation, data governance, logging, traceability, human oversight, accuracy and robustness, testing evidence, AI literacy.

    Week 3-4
    Two outlines of the same shape laid over each other, the part that does not overlap hatched in yellow: the distance between what the Act requires and what is in place.
  4. 4

    4. Documentation and evidence

    Write the technical documentation pack, specify the logging and oversight architecture, and assemble the testing evidence file. Review with your legal counsel or our legal partner.

    In a project, weeks 4-7
    A binder with five index tabs on its edge, one tab yellow: the technical documentation and testing evidence filed where an auditor can find them.
  5. 5

    5. Remediation roadmap and handover

    Deliver the costed roadmap with owners and sequencing, brief leadership, and set the review cadence that keeps documentation current as systems change.

    In a project, weeks 7-8, then quarterly review
    A timeline with five milestones, the last one yellow, and a small box passed along an arrow: the costed roadmap handed over, with an owner for each item and a review date.
How to start

Pick the way in that fits your budget and timing.

Every practice has a free first step, an entry package with a written deliverable and its price listed here, and a full project or retainer quoted after a first call. Once the scope is agreed, the price is fixed, with no hidden costs.

  1. 1
    Step 1 · Free

    Intro call or self-assessment

    60 minutes · 1 engineer · no obligation

    Free
    Show details
    • Intro call with an engineer, or the online self-assessment
    • A written next step within one business day
    • No obligation and no sales deck
    Talk to an engineer
  2. Recommended
    2
    Step 2 · Entry package

    EU AI Act Gap Analysis

    1 AI system · up to 4 weeks from scoping

    from EUR 5,600 net

    The price is fixed once the scope is agreed on the intro call, no hidden costs; extras only from the Not included list.

    Show details
    • Risk classification of one AI system
    • Inventory of the system and its data flows
    • Gap analysis against the technical requirements
    • 30-60-90 day action map
    • Not included: Legal opinion and representation before authorities, full Annex IV technical documentation, third-party conformity assessment, high-risk systems in the provider role.
    • Eligible for BUR / KFS co-funding, subject to operator rules
    Ask for this package
  3. 3
    Step 3 · Project or retainer

    Full scope, quoted after a first call

    Full scope · phased delivery · quoted per phase

    from EUR 18,700 net, quoted after a first call
    Show details
    • Full technical compliance program for one system
    • Documentation and adversarial test evidence
    • Logging and human oversight design
    Start the conversation
Sounds familiar?

The situations that bring teams to this service.

  • Nobody can produce a list of the AI systems your organization actually runs, let alone their risk classification
  • A client, tender or auditor asked for AI Act technical documentation and there is nothing written down
  • Your systems log business events but not the model decisions, inputs and versions that traceability requires
Show the other problems (2)
  • Human oversight exists on a slide but no interface, role or escalation path implements it in production
  • Legal counsel gave you the obligations and the engineering team has no idea what to build in response
Who it's for
  • Product startups whose AI feature was just classified as high-risk by a customer's procurement questionnaire
  • Software houses and system integrators who must hand clients AI Act documentation for what they deliver
  • Corporate and public-sector teams deploying purchased AI systems and carrying deployer obligations they did not write
  • Regulated organizations in finance, health, HR, education and critical infrastructure with audit deadlines in front of them
  • Compliance leads, CISOs, CTOs and heads of legal who need technical artifacts their counsel can sign
Failure modes

Where this goes wrong, and what we do about it.

  1. 1. Documentation written once, true for a weekWhat stays with you: documentation generated from the codebase where possible, with a named owner and a trigger tied to releases
    What happens

    Technical documentation gets produced as a project deliverable, signed off and stored. The system then changes, as systems do, and nothing regenerates the document. A year later the file describes an architecture that no longer exists, which is worse than having none, because it is presented as evidence.

    What we do about it

    We derive the parts that can be derived from the repository, so they change when the system changes, and we keep the narrative parts short enough that updating them is realistic. Then we set the review trigger to a release, not a date.

  2. 2. Logs exist and a decision cannot be reconstructedWhat stays with you: one historical decision reconstructed in full, plus the gaps we closed to make it possible
    What happens

    Logging was designed for debugging, so it records what the service did, not what it decided or on what basis. When someone asks why this applicant got this answer in March, the honest reply is that the inputs, the model version and the prompt are no longer recoverable. The obligation is about traceability, and traceability is not the same thing as observability.

    What we do about it

    We check whether a single past decision can be rebuilt end to end, and where it cannot, we add what is missing: version pinning, input capture with the right retention, and a record of the human step. We prove it by reconstructing a real decision from last month.

  3. 3. Human oversight that cannot say noWhat stays with you: documented override path with its measured cost, and evidence it has been exercised at least once
    What happens

    A person is placed in the loop and the process gives them neither the time nor the standing to overrule. They approve because approving is the only path that does not stop the queue. On paper there is oversight, in practice there is a signature, and the difference matters exactly when it is tested.

    What we do about it

    We check what happens when the human disagrees: whether there is a route, how long it takes, and whether anyone has ever used it. Where the route does not exist we design it, and where the workload makes review impossible we say that plainly rather than certifying it.

What you get

Deliverables, not deliverable-shaped slides.

  • AI system inventory with owners, purpose, data flows, model and vendor per system
  • Risk classification per system against the Act's tiers, with the reasoning written out for audit and legal review
  • Technical documentation pack per in-scope system, structured to the Act's requirements
  • Logging, traceability and human oversight specification, with the architectural changes needed to meet it
  • Evaluation evidence file drawn from quality evaluation and code security review of the system, where required
  • Gap analysis and costed remediation roadmap, plus an AI literacy plan mapped to roles
FAQ

Questions procurement teams ask.

No, and we say so plainly. We are an engineering team. We produce the technical artifacts the Act requires - inventory, classification reasoning, documentation, logging and oversight design, testing evidence - and your legal counsel owns the interpretation and the sign-off. Where you have no counsel for this, we bring a legal partner into the engagement and split the work explicitly.
We work against the obligations in force at the time of the engagement and we date every classification and every document. Where the interpretation is genuinely open we flag it as a decision for your counsel rather than guessing, and we always recommend legal confirmation before you rely on a classification externally. The quarterly review keeps the pack current as systems and guidance change.
A typical engagement runs 6-8 weeks from kickoff to a delivered documentation pack and roadmap. Pricing is fixed per engagement, scoped after a first call, and driven by the number of AI systems in scope and how many of them land in the high-risk tier. Inventory and classification alone can be bought as a smaller first step.
Access to the people who own each AI system, existing architecture and data-flow documentation, vendor contracts and DPAs for purchased AI, and any classification or legal analysis already done. We run structured interviews to fill the gaps - most organizations discover during this step that the real inventory is larger than the one on file.
Yes. Deploying an AI system carries its own obligations, separate from those of the organization that built it. We assess what your vendors actually give you, identify what is missing from their documentation, and write the deployer-side artifacts: oversight design, logging, instructions for use, and the questions to put to the vendor before renewal.
Testing evidence is one of the technical artifacts that supports compliance for higher-risk systems. LLM Evaluation produces evaluation results and a scored test set; Security Review covers the code and the application layer. Both hand over findings in a form that drops straight into the documentation pack. You can buy any of them on its own; running them together removes duplicated discovery and produces one consistent evidence trail.
It is a real obligation and it is also the easiest one to close. We map roles to the level of AI understanding each needs, then feed that into a training plan. Our training programs deliver it, and the completion records become part of your compliance evidence.
Remote under NDA by default. Interviews and workshops run on-site where that gets faster answers, at the same price, and we can work entirely inside your own tooling and document systems when material cannot leave the organization.

Talk to an engineer.

Describe where you are with EU AI Act technical compliance. A reply within one business day.

Talk to an engineer
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