AI governance for engineers: controls that leave evidence.

For the people who write the pipeline, the service or the agent: where a governance rule becomes code, what each stage should record, and which obligation that record answers.

Who this is for.

You own the build, the deploy and the pager. Governance tends to reach you as tickets and questionnaires. This route turns it into things you already know how to ship: a policy file the pipeline reads, an eval that can fail the build, a registry the deploy writes to, a guardrail at the enforcement point and a record each of them emits. Read it in order; each step says what it gives you.

  • ML and data engineers
  • Platform and MLOps engineers
  • Application and agent developers
  • Security engineers
  • Site reliability engineers

On the learning path, start at Eval gate in CI, Observability with OpenTelemetry or Policy-as-code with OPA.

New to the field? Read AI governance explained: the definition, the frameworks and where engineering fits.

Three questions you bring.

Each one answered in brief here, and in full in the Body of Knowledge.

  1. What do I actually have to build?

    Five layers, in build order: see it, rule it, test it, contain it, prove it. A team of one builds a thin slice through all five: a registry the deploy writes to, one policy that blocks, one eval gate, an identity and a kill switch per agent, and a structured record from each.

  2. Which tests count as evidence?

    A test whose metrics and thresholds were fixed before the run, whose result is filed against the version it tested, and whose failure blocks the release. For high-risk systems the EU AI Act asks for testing against prior defined metrics and probabilistic thresholds (Art. 9(8)) 1.

  3. What must the running system record?

    Enough to reconstruct any decision: inputs, outputs, model and prompt versions, tool calls and approvals, as structured, timestamped events. A high-risk system must allow the automatic recording of events over its lifetime (Art. 12(1)), and its deployer keeps the logs it controls for at least six months (Art. 26(6)) 1.

Your route through the site.

In reading order: chapters at the section that matters, then the patterns, tools, templates, datasets and figures that turn them into work.

Start this week.

  1. Put one eval in CI that can fail the build, with its threshold in version control. Eval Gate in CI
  2. Have the deploy write a registry entry with an owner and a scope, and block deploys without one. AI system register entry
  3. Emit one structured evidence record per release: version, eval results, approver and date. Evidence record schema
  4. Key each record to an obligation id, so an auditor can query it. The obligation register
  5. Score your five layers with the self-check and pick one move. Maturity self-check

The obligations that matter most.

The duties a pipeline evidences directly: logging, testing, robustness, documentation, oversight by design, transparency, and the threat lists the evals run against.

What switches on, and whenThe obligations that matter most on the Engineers route, on the dates they first apply and on their later steps, against the register's review date.First appliesIn forceDeferredLater stepAhead1already applies2026-08-02As of 2026-09-245still to come2026-12-022027-12-022028-08-022030-08-02EU AI Act Art. 50 · applies from 2026-08-02 · In forceArt. 50Art. 50EU AI Act Art. 11 · applies from 2027-12-02 · DeferredArt. 11EU AI Act Art. 12 · applies from 2027-12-02 · DeferredArt. 12EU AI Act Art. 14 · applies from 2027-12-02 · DeferredArt. 14EU AI Act Art. 15 · applies from 2027-12-02 · DeferredArt. 15EU AI Act Art. 9 · applies from 2027-12-02 · DeferredArt. 9Art. 11Art. 12Art. 14Art. 15Art. 9Art. 11Art. 12Art. 14Art. 15Art. 93 without a date (Voluntary)Source: the obligation register(/obligations)As of 2026-09-24
What switches on, and whenThe obligations that matter most on the Engineers route, on the dates they first apply and on their later steps, against the register's review date.First appliesIn forceDeferredLater stepAheadDateits place on the time axis1already applies5still to come2026202720282029203020312026-08-022026-12-022027-12-022028-08-022030-08-02EU AI Act Art. 50 · applies from 2026-08-02 · In forceArt. 50Art. 50EU AI Act Art. 11 · applies from 2027-12-02 · DeferredArt. 11EU AI Act Art. 12 · applies from 2027-12-02 · DeferredArt. 12EU AI Act Art. 14 · applies from 2027-12-02 · DeferredArt. 14EU AI Act Art. 15 · applies from 2027-12-02 · DeferredArt. 15EU AI Act Art. 9 · applies from 2027-12-02 · DeferredArt. 9Art. 11Art. 12Art. 14Art. 15Art. 9Art. 11Art. 12Art. 14Art. 15Art. 9As of 2026-09-243 without a date (Voluntary)Source: the obligation register (/obligations)As of 2026-09-24
What switches on, and when The obligations of this route on the date each first applies, drawn by status, and on its later dated steps (a square, filled once reached); the dashed line is the date the rows were last reviewed. Treat what comes before the line as work for now, and read what comes after it as the time left to prepare.
Data table
When the obligations on the Engineers route apply
DateObligationStepStatus
2026-08-02EU AI Act Art. 50: transparency for certain AI systemsApplies fromIn force
2026-12-02EU AI Act Art. 50: transparency for certain AI systemsLater step: Marking grace for existing systems endsIn force
2027-12-02EU AI Act Art. 11: technical documentation (Annex IV)Applies fromDeferred
2027-12-02EU AI Act Art. 12: record-keeping and loggingApplies fromDeferred
2027-12-02EU AI Act Art. 14: human oversightApplies fromDeferred
2027-12-02EU AI Act Art. 15: accuracy, robustness and cybersecurityApplies fromDeferred
2027-12-02EU AI Act Art. 9: risk management systemApplies fromDeferred
2028-08-02EU AI Act Art. 11: technical documentation (Annex IV)Later step: Applies to Annex I embedded (product safety-component) systemsDeferred
2028-08-02EU AI Act Art. 12: record-keeping and loggingLater step: Applies to Annex I embedded (product safety-component) systemsDeferred
2028-08-02EU AI Act Art. 14: human oversightLater step: Applies to Annex I embedded (product safety-component) systemsDeferred
2028-08-02EU AI Act Art. 15: accuracy, robustness and cybersecurityLater step: Applies to Annex I embedded (product safety-component) systemsDeferred
2028-08-02EU AI Act Art. 9: risk management systemLater step: Applies to Annex I embedded (product safety-component) systemsDeferred
2030-08-02EU AI Act Art. 11: technical documentation (Annex IV)Later step: Deadline for legacy high-risk systems intended for use by public authorities (Art. 111(2))Deferred
2030-08-02EU AI Act Art. 12: record-keeping and loggingLater step: Deadline for legacy high-risk systems intended for use by public authorities (Art. 111(2))Deferred
2030-08-02EU AI Act Art. 14: human oversightLater step: Deadline for legacy high-risk systems intended for use by public authorities (Art. 111(2))Deferred
2030-08-02EU AI Act Art. 15: accuracy, robustness and cybersecurityLater step: Deadline for legacy high-risk systems intended for use by public authorities (Art. 111(2))Deferred
2030-08-02EU AI Act Art. 9: risk management systemLater step: Deadline for legacy high-risk systems intended for use by public authorities (Art. 111(2))Deferred
No dateOWASP Top 10 for LLM Applications 2026Voluntary
No dateOWASP Top 10 for Agentic Applications 2026Voluntary
No dateNIST AI RMF MEASUREVoluntary
Obligations for this route (Engineers), with status, date and evidence
Obligation Applies Evidence
EU AI Act Art. 12 record-keeping and logging AIGE-OBL-EUAIA-ART12 Deferred · Structured, signed logs; OpenTelemetry traces; tamper-evident event store
EU AI Act Art. 15 accuracy, robustness and cybersecurity AIGE-OBL-EUAIA-ART15 Deferred · Eval gate; adversarial red-team suite; robustness and security controls; regression evals
EU AI Act Art. 9 risk management system AIGE-OBL-EUAIA-ART9 Deferred · Risk register as code; threat models; linkage to FRIA and eval results
EU AI Act Art. 11 technical documentation (Annex IV) AIGE-OBL-EUAIA-ART11 Deferred · AIBOM (CycloneDX ML-BOM, SPDX 3.0 AI); auto-generated technical documentation; model cards
EU AI Act Art. 14 human oversight AIGE-OBL-EUAIA-ART14 Deferred · Human-in-the-loop checkpoints; kill switch; override and escalation paths
EU AI Act Art. 50 transparency for certain AI systems AIGE-OBL-EUAIA-ART50 In force · Content labelling and machine-readable marking (e.g. C2PA-style); chatbot disclosure banner
OWASP LLM · Top 10 for LLM Applications 2026 AIGE-OBL-OWASP-LLM Voluntary Prompt-injection and output-handling controls; eval gate
OWASP Agentic · Top 10 for Agentic Applications 2026 AIGE-OBL-OWASP-AGENTIC Voluntary Agent threat model; adversarial evals; runtime guardrails; kill switch
NIST AI RMF · MEASURE AIGE-OBL-NISTRMF-MEASURE Voluntary Eval gates; adversarial red-team suite; metrics per failure mode

Every obligation in the register

Sources

  1. [1] Regulation (EU) 2024/1689 (Artificial Intelligence Act), consolidated text of 27 July 2026 (Arts. 9(8), 12(1) and 26(6)). Publications Office of the EU (EUR-Lex). 2026-07-27. https://eur-lex.europa.eu/eli/reg/2024/1689/2026-07-27/eng (verified: primary)

Start at the top of the route.

Step 01 is The stack, layer by layer. Each step after it builds on the one before.