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    AI Governance Policy Builder (EU AI Act, ISO 42001)

    2

    Stand up an AI governance program — classify your AI by risk and map it to the EU AI Act, NIST AI RMF, and ISO/IEC 42001. Guidance, not legal advice.

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    AI Governance Policy Builder (EU AI Act, ISO 42001)

    AI Governance Policy Builder (EU AI Act, ISO 42001)

    Example session with this skill installed

    We are a retail company deploying a third-party AI tool for resume screening in our HR department. We operate in the EU. Classify our risk under the EU AI Act and outline the controls we need.

    • Read your context and instructions
    • Compiled the ai governance policy

    I have analyzed your HR resume screening tool deployment. As you are using a third-party tool in a professional context, you are primarily classified as a

    Deployer under the EU AI Act.

    AI Governance Assessment: HR Resume Screening

    CategoryDetail
    System NameHR Recruitment AI (Third-party)
    EU AI Act TierHigh-Risk (Annex III: Employment, workers management and access to self-employment)
    Organisational RoleDeployer (User)
    Primary FrameworksEU AI Act Art. 26 (deployer obligations) + Art. 27 (Fundamental Rights Impact Assessment, where applicable); NIST AI RMF (Map, Govern); ISO/IEC 42001 §8 (Operational Planning and Control)
    Data SensitivityHigh (candidate PII, potential special-category data if the tool infers protected characteristics)

    Required Governance Controls

    Human oversight: Assign a named reviewer with authority to override or reject AI-driven screening outcomes before any hiring decision is finalized (Art. 26(2)).

    Instructions compliance: Confirm use strictly follows the third-party provider's instructions for use; document any deviation (Art. 26(1)).

    Input data governance: Where you control input data (e.g., CVs, scoring criteria), ensure it is relevant and representative for the tool's intended purpose.

    • Log retention: Retain automatically generated logs for at least six months (Art. 26(6)).

    Worker notification: Inform affected candidates and, where applicable, workers' representatives that an AI system is used in the recruitment process.

    Fundamental Rights Impact Assessment (FRIA): Confirm whether your organisation falls within the categories required to complete a FRIA before deployment (Art. 27) — applies to certain public bodies and private entities providing public services; verify applicability for your case.

    ISO/IEC 42001 alignment: Document this system in your AI asset register, map it to operational controls (§8), and include it in ongoing performance evaluation (§9).

    Note on timing: Annex III high-risk obligations for employment-related AI were extended by the Digital Omnibus — verify the current applicable date for your system category at eur-lex.europa.eu before treating any deadline as fixed.

    Next steps

    1. Add this system to your AI asset register with the High-Risk (Annex III) tier and Deployer role recorded.
    2. Confirm with the third-party provider whether they have completed conformity assessment and CE marking as a high-risk AI provider.
    3. Determine FRIA applicability for your organisation type before go-live.
    4. Draft or update your AI usage policy to disclose AI-assisted screening to candidates.

    Connects securely to your tools. The creator never sees your data.

    What you get

    Classify AI systems into regulatory risk tiers like High-Risk or GPAI.Draft organisational AI usage policies for employees and contractors.Map internal controls to ISO/IEC 42001 and NIST AI RMF functions.Build an AI asset register to track ownership and deployment status.Identify governance gaps before internal audits or regulatory reviews.

    About this skill

    A governance-in-a-box advisor for teams putting AI oversight in place. From your inventory of AI systems and a little context, it classifies each system by risk against the EU AI Act tiers (including Annex III high-risk and general-purpose AI), builds a reusable AI asset register, drafts an acceptable-use policy, and assembles a governance framework — roles, lifecycle gates, oversight — aligned to the NIST AI RMF, with a control crosswalk to ISO/IEC 42001 and the evidence to keep.

    It's for the person handed "get us AI-governance-ready" — a CISO, DPO, compliance lead, or founder — who needs structured starting-point artifacts fast, not a blank page or a generic template. Use it to stand up a program from scratch, classify systems against the EU AI Act, inventory shadow AI, draft an AI usage policy, or find the gaps in a posture you already have.

    It is guidance, not legal advice. Outputs are starting points for a qualified lawyer, DPO, or compliance professional to review before adoption — it does not determine your legal obligations or certify compliance, and it won't understate a system's risk tier to reduce obligations. Because AI regulation is phased and moving, it never bakes in a deadline or penalty figure; it points every regulatory specific to the official source to confirm for your category. It aligns you to ISO/IEC 42001 but does not replace third-party certification, technical AI-security testing, or SOC 2 / ISO 27001 audit readiness.

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