The six-phase compliance journey
Every system moves through six gate-locked phases — Classify, Scope, Implement, Assess, Register, Monitor — and empty phases never block.
Veritome organises every system's EU AI Act obligations into a six-phase journey, in this fixed order:
- Classify — confirm role, risk tier and prohibited-use screening (Art. 5, Art. 6).
- Scope — applicable obligations confirmed and owned, plus the Art. 4 AI-literacy duty.
- Implement — risk management (Art. 9), data governance (Art. 10), technical documentation (Art. 11 and Annex IV), human oversight (Art. 14, Art. 26(2)) and the rest of the build work.
- Assess — the conformity assessment (Art. 43), the EU declaration of conformity (Art. 47) and CE marking (Art. 48). The fundamental-rights impact assessment (Art. 27), where it applies, sits in Implement: it must be done before deployment, and Assess is locked until Implement is complete.
- Register — the EU database registration (Art. 49, Annex VIII).
- Monitor — post-market monitoring (Art. 72), serious-incident reporting (Art. 73) and the scheduled reviews.
Each obligation belongs to exactly one phase, so a phase is complete when all of its applicable obligations are complete.
Gate locking
Phases are gate-locked: a phase is locked until every earlier phase that has obligations reaches 100%. A locked phase names the phases blocking it, so you always know what to finish first. This mirrors the legal reality — you cannot meaningfully register a system whose conformity assessment is unfinished.
Empty phases
Not every phase applies to every system. A deployer, for example, may have no conformity-assessment obligations at all. Phases with no applicable obligations count as complete automatically and never block later phases — role-specific journeys still reach 100%.
Where you see the journey
- System record — the journey bar in the system header shows each phase's status; the Obligations tab filters by phase and explains a locked one.
- AI systems — the register's Journey column shows each system's current phase with done over total.
- Dashboard — the Programmes panel carries the EU AI Act journey as its first row: the system furthest behind, its phase, and the next obligation to work.
A brand-new system whose obligations have not been generated yet shows every phase as pending, not complete — the gate never reads an un-scoped system as finished. Phase progress updates automatically as you complete obligations.
The standards you switch on borrow the same rule: each programme runs in gated phases of its own. See Phases and gates: why the next step is locked.