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Will Lassalle
The Governance Gap

Issue #5

The AI Governance Deadline Boards Can’t Delegate

Most companies think they have an AI strategy; very few have an AI accountability system that would survive a regulatory test or a board inquiry.

Editor's note — September 12, 2026: Corrected the blanket high-risk deadline and removed an unidentified U.S. order reference. The original publication date and URL are retained.

The take

AI governance requires ownership and evidence, but a single countdown does not describe the EU AI Act.

The European Commission's timetable, reviewed September 12, 2026, lists December 2, 2027 for specified Annex III high-risk uses and August 2, 2028 for high-risk AI embedded in regulated products. Other provisions have separate application dates. This does not mean that all obligations were postponed.

Questions for management

  • Which systems, legal entities and uses fall within scope?
  • What category and application date has counsel identified for each?
  • Who owns the controls, evidence and remediation decisions?
  • How will material changes trigger a new assessment?

My recommendation is to connect the legal applicability assessment with the actual inventory and operating controls. A policy and a deadline calendar alone cannot demonstrate readiness.

Source and further reading: Primary reference. Framework guidance is not a statement that a particular law applies to every organization.