AI governance

Your AI systems respect your access rules, from day one

A poorly scoped chatbot can expose the leadership team's salaries to a production operator. A misconfigured RAG can reveal confidential legal-committee notes to a salesperson. At IgnitionAI, access control is part of the architecture, not a layer bolted on afterwards.

The regulatory references cited on this page link to the official text on EUR-Lex. Cost and duration estimates are tagged as such. See our editorial policy.

The EU Regulation 2024/1689 on artificial intelligence came into force on 1 August 2024. Its obligations apply progressively: the prohibited practices of Article 5 since February 2025, general-purpose models since August 2025, the Article 50 transparency obligations (chatbots, generated content) on 2 August 2026, high-risk Annex III systems on 2 December 2027 and Annex I systems on 2 August 2028. The Annex III and Annex I dates were postponed by the Digital Omnibus (political agreement of 7 May 2026) to allow the harmonised technical standards to be finalised.

French mid-market companies deploying AI systems in production must build a registry of their systems, classify each one by risk level, document automated decisions and organise human oversight. Penalties run up to €35 million or 7% of worldwide turnover for breaches of the prohibited practices of Article 5 (Article 99(3)).

In regulated sectors, these obligations come on top of a demanding existing framework: ACPR for banking and insurance, HAS and HDS for healthcare, ANSSI for cybersecurity, CNIL for data protection. Our approach plugs into your existing compliance setup.

Four pillars

The scope covered by each engagement

Inheriting existing permissions

Your chatbots and RAG build on your Active Directory, your IAM or your business RBAC model. A production operator querying an agent only retrieves documents they could already access in your applications. No AI channel that bypasses your access rules.

AI Act and sector compliance

Documentation compliant with EU Regulation 2024/1689: system classification by risk level (Articles 5, 6, 50), AI system registry, technical sheets per Annex IV, traceability of automated decisions under Article 12. Sector adaptations for banking and insurance (ACPR, DORA), healthcare (HAS, HDS), public sector (RGS).

Data governance and GDPR

Lineage of the data ingested into your RAG. Targeted erasure mechanisms to answer the right to be forgotten (Article 17 of the GDPR) without full reindexing. Anonymisation and pseudonymisation during development phases. Regular audit of the data accessible to the systems.

Technical and organisational governance

A three-tier organisational architecture: strategic committee at executive level, monthly operational steering committee, technical centre of excellence. Applying ANSSI's 35 security recommendations for generative AI systems. Processes for model updates and for retiring a failing AI system.

Standards and frameworks

What we build on

Our methodology aggregates the requirements of the main frameworks that apply to your context. ISO/IEC 42001:2023 certification is the operational foundation we recommend: it covers 80 to 85% of the AI Act's requirements and provides an auditable framework independent of the European regulatory timeline.

Certifiable standard

ISO/IEC 42001:2023

The first certifiable international standard dedicated to AI management systems. Covers 80 to 85% of the AI Act's requirements. The reference standard to demonstrate structured AI governance to auditors and regulators.

EU regulation

EU Regulation 2024/1689 (AI Act)

The European regulatory framework on AI, amended by the Digital Omnibus of 7 May 2026. Classification by risk level (unacceptable, high, limited, minimal), specific obligations for general-purpose models.

Financial sector

EU Regulation 2022/2554 (DORA)

The Digital Operational Resilience Act, applicable since 17 January 2025 to the financial sector. Four pillars: ICT risk management, incident reporting, resilience testing, ICT third-party management. Strengthens the supervision of AI systems in banking and insurance.

FR cybersecurity

ANSSI's 35 recommendations

A security guide for generative AI systems published by ANSSI in April 2024, updated in 2025. The French reference for securing AI architectures from design to deployment.

Standard deliverables

Eight documents included in every production rollout

  • An AI system registry structured to meet AI Act requirements (Articles 49, 71 of EU Regulation 2024/1689)
  • Risk-level classification of each delivered system (minimal, limited, high, unacceptable within the meaning of Articles 5, 6 and 50)
  • A technical file compliant with Annex IV: description, data, performance, risk management, modifications, cybersecurity
  • Access mapping: who can query what, on which data, in what context
  • Documentation of automated decisions and an explanation procedure for the people concerned
  • A usage charter and terms of use for end users
  • An AI incident response plan: detection, escalation, rollback, notification under Article 33 of the GDPR if applicable
  • A review schedule and annual system update plan

Frequently asked questions

What DPOs, CISOs and audit committees ask

How does an enterprise chatbot or RAG secure access to internal documents?

Access control is set up at several levels. At the vector-store level, each document chunk is tagged with its original ACLs. At query time, the system filters results according to the authenticated user's permissions, retrieved from your Active Directory or your IAM. No out-of-scope document is passed to the LLM in the context. This approach is detailed in our article on RAG access-control architectures.

What does the European AI Act concretely require of companies?

EU Regulation 2024/1689 classifies each AI system by its risk level. High-risk systems listed in Annex III (employment, credit scoring, access to essential services, etc.) must comply with Articles 9 to 15: risk management, data governance, technical documentation, logging, transparency, human oversight, accuracy and cybersecurity. Chatbots and generative systems have a transparency obligation under Article 50. The Digital Omnibus of 7 May 2026 postponed the application of the Annex III obligations to 2 December 2027 (instead of 2 August 2026) to allow technical standards to be finalised. Penalties, set out in Article 99, run up to €35 million or 7% of worldwide turnover for breaches of Article 5 (prohibited practices), €15 million or 3% for the other obligations.

Does a mid-market company need a dedicated AI steering committee?

IgnitionAI estimate based on 8 engagements run in 2024-2025: once at least two AI systems are deployed in production, a steering committee is useful. It typically brings together the DPO, the CISO, a representative from risk management, a business sponsor and a technical lead. The frequency varies with the number of systems: quarterly for two to three systems, monthly beyond five. The European regulation does not explicitly require such a committee of deployers; it becomes necessary in practice to meet the Article 14 (human oversight) and Article 9 (risk management) obligations.

Does the GDPR right to be forgotten apply to data indexed in a RAG?

Yes. Article 17 of EU Regulation 2016/679 (GDPR) provides for the right to erasure of personal data, applicable even when that data is ingested into a vector store or used to train a model. The architectures we design include a targeted erasure mechanism that removes the corresponding vectors without full reindexing. For fine-tuned models, the answer depends on the type of data and whether the weights are identifying, and is analysed case by case with your DPO.

How do you align AI governance with existing data governance?

AI governance builds on the data governance already in place. The data catalog references the datasets used by the AI systems. Classification policies (public, internal, confidential, secret) determine which documents an AI system can ingest. Access validation processes extend to the new AI channels. This alignment is documented in a governance map delivered with every engagement.

What does bringing an existing AI system into governance compliance cost?

IgnitionAI estimate based on 8 engagements in 2024-2025: an initial audit of an AI system in production with no compliance documentation takes two to three weeks and costs between €12,000 and €25,000 depending on complexity. The compliance work itself ranges from €15,000 for a simple documentation clean-up to €80,000 if the access architecture needs to be redesigned. These ranges can vary by ±30% depending on your precise context. A firm quote is issued after the audit phase.

Is ISO/IEC 42001 worth it for a mid-market company?

The ISO/IEC 42001:2023 standard is the first certifiable international standard dedicated to AI management systems. For a mid-market company operating at least two AI systems in production, the investment pays off on three counts: it covers 80 to 85% of the AI Act's requirements and so eases upcoming regulatory compliance; it is an assurance signal for your clients and partners, particularly in regulated markets; it structures your AI governance along an independently auditable framework. IgnitionAI estimate: a complete certification process takes between 8 and 14 months for a mid-market company, with a total investment (audit, compliance work, certification by an accredited body) between €40,000 and €120,000 depending on initial maturity.

How do you align the AI Act, GDPR, DORA and NIS2?

These frameworks don't conflict but reinforce one another. The AI Act brings risk classification and technical-documentation obligations. The GDPR covers the protection of personal data used by AI systems. DORA applies to the financial sector and imposes operational resilience. NIS2 targets the cybersecurity of essential and important entities. For multi-framework mid-market companies, the recommended approach is to build a unified governance layer that aggregates the common requirements (system registry, logging, monitoring, incident plan) and identifies the sector-specific ones. ISO/IEC 42001 certification often serves as the operational skeleton for this integrated approach.

How much does an enterprise RAG project cost?

IgnitionAI ranges based on our 2024-2025 engagements: scoping starts around €8,000, a prototype sprint runs between €25,000 and €60,000, and a full production rollout between €80,000 and €250,000 depending on document volume, criticality and the required compliance level — training and code transfer included. Recurring inference costs come on top and are estimated at scoping time. Possible variation of ±30%; a firm quote is issued after the first conversation.

How should an SMB or mid-market company prepare for the AI Act?

Three workstreams to start now: inventory the AI systems in use (including SaaS tools with embedded AI), classify each system by risk level under Annex III, and document the transparency required by Article 50 for chatbots and generated content. The Digital Omnibus of 7 May 2026 postponed the Annex III obligations to 2 December 2027, but prohibited practices (Article 5) and the transparency obligations already apply. Our AI governance white paper details the full timeline and provides the templates.

Why do so many AI projects never reach production?

The recurring causes we observe on our engagements: a POC validated on ten clean documents but never confronted with real volume, inference costs discovered after the fact, no measurable acceptance criteria, and compliance (access rights, GDPR, AI Act) handled at the end of the project when it actually shapes the architecture. That is exactly what the written go/no-go scoping eliminates: every engagement starts with two weeks that price these four risks before the budget is committed.

Should you build your generative-AI project in-house or outsource it?

The right criterion isn't the daily rate but the cost of delay and the risk of learning on your critical project. Outsourcing the build to a senior consultancy and then bringing operations in-house combines both: production in a few months, and your trained teams take over a documented system whose code you fully own. That is our standard model — intellectual-property transfer is contractual.

Can a RAG be deployed sovereignly, without data leaving France?

Yes. We deploy on your infrastructure or on a French sovereign cloud, with self-hosted open-weights models or European models when the context requires it. The data perimeter is contractual: no document is sent to a third-party API outside your control, the data flows are documented for your DPO and CISO, and the architecture is audited against ANSSI's 35 recommendations for generative AI.

Sources and estimates. Regulatory: EU Regulation 2024/1689 (AI Act, amended by the Digital Omnibus of 7 May 2026), Articles 5, 6, 9 to 15, 50, 70, 99, 113, Annexes III and IV; EU Regulation 2016/679 (GDPR) Articles 17 and 33; EU Regulation 2022/2554 (DORA); NIS2 Directive. Standards: ISO/IEC 42001:2023. Technical frameworks: ANSSI's 35 recommendations for generative AI systems (April 2024, updated 2025). French authorities: ACPR, HAS, HDS, ANSSI, CNIL. Cost and duration estimates: based on 8 IgnitionAI engagements in 2024-2025 (industry, public sector, insurance, private healthcare). Possible variation of ±30%. See our full editorial policy.
Enterprise AI governance and access control — IgnitionAI