The implementation of the AI Act has entered a new phase: the European Commission has launched its first formal compliance checks concerning operators in the artificial intelligence sector, sending requests for information to more than 30 companies.

The initiative marks one of the first tangible steps from the adoption of the new EU regulatory framework towards its effective supervision and enforcement. At this stage, however, the requests do not constitute findings or allegations of infringement, nor do they amount to the initiation of sanctioning proceedings. Rather, they are information-gathering measures intended to obtain the elements necessary to assess compliance with the obligations laid down by the EU regulatory framework on artificial intelligence.

The Commission has confirmed that the requests concern two main areas of scrutiny, without disclosing the identity of the companies concerned. This approach reflects the preliminary stage of the exercise: discussions with the companies involved are still ongoing and, at present, no conclusions have been reached as to any potential instances of non-compliance.

The launch of these checks is nevertheless significant for market operators. The AI Act is no longer merely a regulatory framework in respect of which organisations must develop compliance programmes; it is now a body of law in relation to which the European institutions are beginning to exercise in practice the supervisory powers conferred on them by the Regulation.

The Commission’s requests confirm the importance of establishing, from the outset, a documented and auditable AI governance framework, enabling organisations to identify and evidence with precision their role within the AI value chain, the obligations applicable to them, the assessments carried out and the measures adopted to ensure compliance.

The Commission’s initiative is therefore a significant development also for companies that are still completing their AI Act compliance programmes: with the commencement of the first supervisory checks, the ability to respond to regulatory authorities in a timely, consistent and fully documented manner is itself becoming an essential component of AI Act compliance.