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The EU AI Act's Implementation: First 100 Days Impact Assessment

The European Union's AI Act, the world's first comprehensive legal framework for artificial intelligence, has now been in effect for its initial implementation phase. Today marks an important milestone to evaluate how this pioneering legislation is reshaping the global AI landscape.


Key Implementations So Far

The EU AI Act categorizes AI systems based on risk levels, with the most stringent regulations applying to "high-risk" systems that could impact fundamental rights. During these first 100 days, we've witnessed several notable developments:

  • The newly established European Artificial Intelligence Board (EAIB) has published its first set of detailed technical guidelines for compliance assessment.
  • Major AI providers have appointed dedicated AI compliance officers as required by the regulation.
  • The transparency requirements have resulted in more detailed documentation of AI systems, with several companies releasing comprehensive model cards.

Industry Adaptation

Tech companies have responded with varying degrees of agility. Some observations:

  1. Compliance Infrastructure: Larger firms like Microsoft, Google, and Anthropic have developed robust compliance frameworks, often open-sourcing parts of their methodology to help smaller players.

  2. Market Realignment: Some smaller AI startups have pivoted their business models to avoid classification in high-risk categories, while others have embraced the regulatory framework as a competitive advantage.

  3. Global Standards Impact: The Act's extraterritorial scope has influenced AI development practices beyond Europe, creating de facto global standards similar to what occurred with GDPR.

Early Challenges

The implementation hasn't been without friction:

  • Several companies have applied for interpretive guidance on the classification of their systems, creating a backlog for regulators.
  • The requirements for human oversight of high-risk systems have proven costlier than anticipated for some deployments.
  • There remains significant uncertainty around the practical application of the Act's provisions on general-purpose AI systems.

Economic Impact Assessment

Initial economic data suggests a mixed picture:

  • Compliance costs have been substantial, with the average large AI provider reporting approximately €3.2 million in direct implementation expenses.
  • Venture capital investment in European AI companies showed a temporary dip immediately following implementation but has rebounded in recent weeks.
  • A new market for AI compliance tools and services has emerged, creating an estimated 3,800 new specialized jobs across the EU.

Looking Forward

As we move beyond this initial phase, several trends are emerging:

  1. Compliance Standardization: Industry consortia are working to develop shared compliance tools and standards to reduce redundant work.

  2. International Alignment: Preliminary discussions between EU and US regulators suggest potential for greater harmonization of approaches.

  3. Litigation Watch: The first legal challenges to the Act's implementation are expected to emerge in the coming months, which will test the practical interpretation of key provisions.

The EU AI Act represents the most ambitious attempt yet to balance innovation with protection of fundamental rights. While the full impact will take years to materialize, these first 100 days suggest that a regulated AI ecosystem is not only possible but may ultimately create more sustainable innovation pathways.

How the regulatory landscape continues to evolve will significantly impact AI development trajectories worldwide, as companies adapt to what is increasingly becoming a global baseline for responsible AI deployment.

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