Classifies an AI initiative's EU AI Act risk tier and surfaces the regulatory, data-governance, and ethics obligations that follow from it, as a first-pass structuring check rather than a legal opinion. Use before an AI initiative goes to approval, especially one touching employment, credit, biometric, or other high-risk decisions about individuals.
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---
name: responsible-ai-and-governance-check
description: "Classifies an AI initiative's EU AI Act risk tier and surfaces the regulatory, data-governance, and ethics obligations that follow from it, as a first-pass structuring check rather than a legal opinion. Use before an AI initiative goes to approval, especially one touching employment, credit, biometric, or other high-risk decisions about individuals."
---
# Responsible AI & Governance Check
## Purpose
Checks the regulatory, risk, and ethics dimensions of an AI initiative
before it goes to approval. Deeper EU AI Act compliance analysis requires
separate regulatory expertise — this skill is a first-pass structuring
check, not a legal opinion.
## Anchored in research
- EU AI Act (Regulation (EU) 2024/1689)
- LinkedIn 2026 — Risk & Compliance Management
## Method
1. **Classify the system's risk tier under the EU AI Act's risk
pyramid**, as a first-pass, non-binding read:
- **Unacceptable risk (prohibited)** — e.g. social scoring,
manipulative or subliminal techniques, most forms of real-time
remote biometric identification in public spaces. If the
initiative plausibly falls here, stop and escalate to legal
counsel immediately — don't proceed to scoring the rest of the
initiative as if it were a normal risk trade-off.
- **High risk** — systems used in the areas the Act lists in Annex
III (e.g. employment/HR decisions, access to essential services
including credit scoring, education and exam scoring, law
enforcement, biometric categorization, critical infrastructure
management). High-risk classification triggers obligations
around risk management, data governance, technical
documentation, logging, human oversight, and conformity
assessment — flag these as required workstreams, don't estimate
them from memory.
- **Limited risk** — systems with transparency obligations, e.g.
the user must be told they're interacting with AI, or that
content is AI-generated (chatbots, deepfakes, emotion-recognition
systems).
- **Minimal risk** — the majority of AI applications (e.g. spam
filters, most internal productivity copilots) — no additional
obligations beyond general product/consumer law.
Mark the classification `[assumption — verify]` and route it to a
qualified regulatory reviewer before it's treated as final — this
skill's classification is a triage aid, not a determination.
2. **If the initiative is high risk or above, list the concrete
obligations that follow, without estimating their cost or effort
from memory:** a risk-management system, data governance and
quality measures, technical documentation, automatic logging,
human-oversight design, accuracy/robustness/cybersecurity
requirements, and (for certain categories) third-party conformity
assessment before market placement. Route the detailed compliance
work to regulatory/legal expertise — this skill only makes the
obligation list visible early enough to factor into scoping and
timeline.
3. **Check the initiative against a broader ethics lens than pure legal
compliance** — a system can be legally compliant and still cause
real harm or reputational damage:
- **Fairness** — could the training data or the decision logic
produce systematically worse outcomes for a protected group?
Has this been tested, or only assumed absent?
- **Transparency and explainability** — can the organization explain,
in plain language, why the system produced a given output to
someone affected by it?
- **Accountability** — is there a named human owner who is
answerable for the system's outcomes, distinct from whoever built
it?
- **Privacy** — does the system process personal data in a way that
needs a separate GDPR/data-protection assessment (a different,
complementary check from this one — flag it, don't attempt it
here)?
4. **Cross-check the Speed to Value & Governance/Risk score already
assigned in `../ai-opportunity-portfolio/SKILL.md`** against this
deeper check — if the risk tier found here is materially higher than
what that score assumed, flag the mismatch and recommend the score
be revisited rather than silently proceeding.
5. **Produce a structured governance checklist result**: risk tier
(with `[assumption — verify]` where applicable), triggered
obligations, ethics-lens findings, open questions requiring legal
sign-off (see `../../references/` once a template is added).
6. Validate the result with stakeholders or your own experience-based
checklist, and route anything above minimal risk to qualified
regulatory counsel before the initiative proceeds to approval.
## What this skill does NOT do
- Doesn't make the final decision for you — it produces a structured
draft to support a human decision.
- Doesn't confirm figures, market data, or competitor data from
memory — it uses the inputs you provide, or marks an assumption
clearly (`[assumption — verify]`).
- Doesn't give a legally binding interpretation of the AI Act — it
surfaces the risks and routes the initiative to deeper compliance
analysis; only qualified legal counsel can give a binding
classification or sign-off.
- Doesn't perform a GDPR/data-protection assessment — that's a
distinct, complementary check; this skill only flags when one is
needed.
## Refinement notes
Areas to keep deepening with real practice:
- your own rules of thumb and heuristics for this technique — e.g.
which initiative types most often turn out higher-risk than they
first appear
- concrete templates (into `../../references/`, e.g. a governance
checklist template)
- reference cases / your own examples
- what this skill deliberately does *not* do (guardrails, common
mistakes) — add to the list above
Once this section is filled in and validated in practice, update the
`maturity` field in `skills_index.json` to `draft`, `validated`, or
`canonical` (see `../../../meta/maturity_levels.md`). **Don't add new
fields to the frontmatter** — `name` and `description` are the only
ones allowed (see `../../../meta/frontmatter_schema.md`).
## Continue from here
- Next in this pack: `../build-vs-buy-vs-partner-ai/SKILL.md` —
structures the decision to build in-house, buy off a platform, or
partner on an AI solution.
- If the deployer is a public body: the transparency, fairness, and
human-oversight bar is generally higher for citizen-facing decisions —
see
`../../../specialisation-packs/public-sector-ai-service-design/skills/ps-regulatory-and-ethical-guardrails-for-public-ai/SKILL.md`
for the public-sector-specific triage on top of this check, and
`../../../specialisation-packs/public-sector-ai-service-design/skills/ps-community-and-equity-impact-assessment/SKILL.md`
for the differential-impact check referenced in step 3's fairness
lens.
- A ready-made skill chain for this situation: see `../../../playbooks/`
- This pack's shared guardrails: `../../CLAUDE.md`
## References
- `../../references/` — the pack's shared background material
- `../../CLAUDE.md` — the pack's shared guardrails