ActComply vs Trustible: EU AI Act compliance

If your startup ships AI features in Europe, the EU AI Act is now a product team problem, not just a governance committee topic. Trustible has built a reputation helping enterprises create AI governance frameworks and structured board reporting. That is valuable at scale. But for a CTO or Head of Product at a 20-500 person EU startup, what you need is direct, article-level clarity: does our AI system qualify as high-risk under Annex III, what documentation do we need under Article 9 and Article 11, and what is the fastest path to demonstrating compliance before auditors or enterprise customers ask.

What the EU AI Act requires

The EU AI Act creates a tiered obligation structure based on risk. High-risk AI systems listed in Annex III (covering recruitment, credit scoring, biometric categorisation, education, and more) must meet requirements including a risk management system (Article 9), documented data governance (Article 10), technical documentation (Article 11), transparency disclosures to users (Article 13), human oversight mechanisms (Article 14), and a quality management system (Article 17). The compliance deadline for these Annex III systems is December 2, 2027. If your product includes general-purpose AI model components, GPAI obligations under Article 53 apply from August 2, 2026, with fines of up to EUR 15 million or 3% of global annual revenue.

What this means for your business

Trustible is designed to help organisations build AI governance programs, produce audit trails for boards, and demonstrate responsible AI use at an enterprise level. For a startup product team, this creates friction: you need to translate governance language into engineering tasks, map abstract frameworks to the specific articles that apply to your system, and do it fast. If your AI feature touches recruitment, lending, or healthcare, you are looking at concrete Annex III obligations that require documented evidence, not just a governance posture. ActComply maps your system directly to the articles that apply, generates the documentation templates you need, and tells you exactly which obligations are active for your risk classification.

Steps to get compliant

1. Classify your system: run your AI feature through the ActComply risk screener to determine whether it falls under Annex III, the GPAI rules, or the lower-risk transparency obligations under Article 50.
2. Map your obligations: once classified, identify the specific articles that apply and what evidence or documentation each requires.
3. Build your compliance documentation: use ActComply templates to produce the technical documentation (Article 11), risk management records (Article 9), and human oversight policies (Article 14) that regulators and enterprise procurement teams will request.
4. Set a review cadence: EU AI Act compliance is not a one-time checkbox. Schedule quarterly reviews as your product evolves and as secondary delegated acts are published.

Free EU AI Act risk assessment

Not sure where your AI system stands? The free ActComply risk screener classifies your system in under 5 minutes. No sign-up required.