Unified Governance Page EU AI Act • OpenAI Preparedness • CRSP AER

Align Legal Obligations, Frontier Safety Gates, and Interaction Governance

This page explains how three layers work together: EU AI Act (what the law requires), OpenAI Preparedness Framework (frontier severe-harm release gating), and CRSP AER (per-interaction governance: Ask → Evidence → Release). Use it to design compliant AI deployments that remain safe at runtime—conversation by conversation.

EU AI Act (implementation milestones)

EU
Entry into force 1 Aug 2024 Phased application with exceptions.
Prohibitions apply: 2 Feb 2025 GPAI obligations: 2 Aug 2025 Fully applicable: 2 Aug 2026

Use these milestones to schedule compliance deliverables and audit gates.

OpenAI Preparedness Framework (v2)

PF
Severe-harm gating Threat models + capability evaluations + safeguards before release. Version 2 last updated: 15 Apr 2025.
Threat modeling Capability elicitation Safeguard evaluation

Use PF as your model-level “frontier gate” that informs deployment restrictions.

CRSP AER (runtime governance)

AER
Interaction loop ASK → EVIDENCE → PROPOSE → ENTITLE → RELEASE Constrains and audits each output before release.
Defeaters Entitlements Audit log

Use AER to enforce scope, uncertainty, and accountability per response.

The three-layer stack

Legal → frontier gate → runtime gate
Layer 1 (EU AI Act): Defines legal obligations by risk tier + phased applicability. Layer 2 (Preparedness): Defines severe-harm capability evaluations + release safeguards. Layer 3 (CRSP AER): Enforces per-interaction constraints (defeaters, required checks, auditability).

The practical payoff: even if you are compliant on paper and your model is released safely, you still need a runtime mechanism that prevents overreach, scope creep, and “authority leakage” in each output. AER is that mechanism.

EU AI Act: what to operationalize

Risk tiering + transparency + governance timeline

Operational interpretation

Treat the EU AI Act as a set of obligations you must demonstrate (documentation, transparency, controls), and boundaries you must not cross (prohibited practices and constraints for sensitive deployments). Your internal program should bind these obligations to concrete artifacts: system registers, risk classification, user transparency notices, post-market monitoring, and change-control.

🧾
Evidence posture EU compliance is documentation-driven. Build audit-ready artifacts early.
⛔
Boundary posture Hard prohibitions require reliable enforcement—not just policy text.

Timeline (practical)

Date Milestone How to use it
1 Aug 2024 Act enters into force Start governance program + inventory systems
2 Feb 2025 Prohibited practices + AI literacy obligations apply Enforce hard blocks + training + UX restrictions
2 Aug 2025 Governance rules + GPAI obligations apply Provider documentation + transparency controls
2 Aug 2026 Fully applicable (general) Full control coverage across applicable systems

Keep this table aligned to official EU sources and legal counsel.

OpenAI Preparedness: what to operationalize

Frontier severe-harm gates + deployment safeguards

PF as your “frontier gate”

Treat Preparedness as your model-level gate that defines: (1) which severe-harm domains you evaluate, (2) how you elicit and measure capabilities, (3) what safeguards are required before deployment, and (4) what conditions trigger delayed release or additional mitigations.

Threat model register Capability eval suite Safeguard verification Release gate memo

Where PF ends (and AER begins)

Preparedness primarily governs model-level release conditions. It does not, by itself, guarantee that a particular user prompt won’t induce unsafe or non-compliant reasoning. That’s where CRSP AER runs: it applies your constraints at runtime and produces audit-ready traces.

PF answers: "Should we deploy this capability?" AER answers: "Should we release THIS output?"

CRSP AER: per-interaction control plane

Defeaters + entitlements + release gating

AER phases (what each must enforce)

Phase Goal Minimum required outputs (typical)
ASK Clarify task + constraints + audience Scope statement; risk posture; prohibited moves
EVIDENCE Ground claims; surface uncertainty Facts; assumptions; uncertainties; alternatives
PROPOSE Draft provisional artifact Non-directive output; review points; options
ENTITLE Run defeaters; verify required checks Defeater scan; completeness checks; decision
RELEASE Publish only entitled content Final artifact + audit notes + next checks

Defeaters (examples)

Defeaters are conditions that automatically invalidate entitlement to release. They prevent “helpfulness drift” and provide explainable refusals.

Common defeaters: - AI-as-authority (output implies autonomous decision authority) - Missing uncertainty (required uncertainty omitted) - Scope creep (output enables prohibited/untested use) - Missing monitoring (no audit/monitoring plan where required) - High-stakes action guidance (clinical/legal/financial directives)

Crosswalk: EU AI Act × Preparedness × CRSP AER

How to build an end-to-end control story
Control Theme EU AI Act (legal) OpenAI Preparedness (model gate) CRSP AER (runtime gate)
Risk classification Classify system risk tier and obligations Threat models + capability categories Assign interaction risk posture; constrain moves
Prohibitions / boundaries Prohibited practices must be blocked Restrict deployment above capability thresholds Defeaters prevent disallowed outputs per prompt
Transparency User-facing transparency duties in relevant contexts Document evaluations/safeguards Require disclosures, limits, and audit notes per response
Monitoring Ongoing compliance posture for applicable systems Safeguard evaluation and post-release monitoring expectations Required checks: audit fields + monitoring plan + review cadence
Change control Maintain evidence for updates affecting obligations Re-evaluate safeguards as capability changes Version tags + entitlement gates before release

Practical rule: EU AI Act defines obligations, Preparedness defines frontier deployment gates, and AER ensures each output is entitled under your obligations and gates.

Implementation checklist

What to build (policy + engineering)

Governance artifacts

  • System register: use-case, owner, intended users, jurisdictions
  • Risk map: EU AI Act tier + Preparedness hazard class + internal risk rating
  • Scope / Non-scope: explicit prohibitions and “must not” uses
  • Transparency text: user notices, logging disclosure, limitations
  • Change control: versioning, approvals, rollback triggers

Runtime controls (AER-first)

  • ASK gate: enforce constraint declarations (no hidden scope)
  • EVIDENCE gate: facts/assumptions/uncertainty required for high-risk outputs
  • ENTITLE gate: defeater library + required checks (audit/monitoring)
  • RELEASE gate: output only if entitled + audit log written
  • Review cadence: committee review of defeater hit-rates and near-miss reports

Template: AER-ready governance prompt

Paste this into your governed agents
SYSTEM (AER Charter): You are operating under CRSP AER runtime governance. You are not an authority; you draft provisional artifacts only. You must output: ASK, EVIDENCE, PROPOSE, ENTITLE, RELEASE. If any defeater is triggered, do not RELEASE—revise or refuse. USER (Task): Artifact type: [policy memo | misuse scan | transparency notice] Audience: [review body] Constraints: [forbidden moves] Sensitive data posture: [none | hypothetical | PHI/PII constraints] Prompt: [task text]

Tip: For regulated domains, attach committee charter + model/system spec as explicit artifacts.

Sources (primary)

Put these links in your compliance repo

Official references

  • EU Commission “Shaping Europe’s digital future” — AI Act policy page (timeline milestones)
  • European Commission news: “AI Act enters into force” (1 Aug 2024)
  • OpenAI Preparedness Framework v2 (PDF, last updated 15 Apr 2025)
  • OpenAI blog: “Our updated Preparedness Framework”
Links (for your repo): - https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai - https://commission.europa.eu/news-and-media/news/ai-act-enters-force-2024-08-01_en - https://cdn.openai.com/pdf/18a02b5d-6b67-4cec-ab64-68cdfbddebcd/preparedness-framework-v2.pdf - https://openai.com/index/updating-our-preparedness-framework/