EU AI Code of Practice Is Now Live – Time To Act – Artificial Lawyer

By Wayne Cleghorn, Partner at Excello Law.

Companies in the UK, EU, US and beyond must get a firm grasp of the AI systems they develop, deploy or use. The European Union’s General-Purpose AI Code of Practice officially came into effect last week, a year after the EU AI Act became law. Wayne Cleghorn, a partner at Excello Law and member of the working group that shaped the Code of Practice, is urging businesses to act now to assess whether their AI systems fall within the scope of the new regime.

The Code of Practice, published by the European Commission and the EU AI Office, marks a significant step in the implementation of the EU AI Act, the world’s first comprehensive legal framework for artificial intelligence. It sets out voluntary, but influential standards for General-Purpose AI (GPAI) systems.

Here is his view:

‘The work to produce the Code of Practice was a world first. It was intensive, technical, and fast-paced. The final text represents a consensus built under real time pressure. It’s a best-effort starting point, and while it will need to evolve, it establishes foundational norms for AI governance.

Although the Code is voluntary, organisations that sign it will benefit from simplified enforcement procedures under the EU AI Act. However, even those who choose not to sign must still demonstrate compliance with the relevant legal requirements under the Act.

The reach of the EU AI Act is not limited to EU-based businesses. UK companies, including those building or deploying AI systems that enter the EU market, could be directly impacted. It’s crucial to assess whether your AI systems fall into categories of ‘unacceptable’, ‘high’, ‘limited’, or ‘minimal risk’ as defined under the Act, and then apply the relevant compliance obligations.

The EU AI Act, which became law on 1 August 2024, is being phased in over several years. August 2025 marks a critical implementation milestone: all 27 EU member states must now appoint Notifying Authorities and Market Surveillance Authorities, publish local penalty frameworks, and report on the readiness of their national AI oversight infrastructure.

This phase will reveal the real-world scale of the EU’s AI regulatory framework. It will also give UK and international businesses insight into how each member state intends to enforce the law, and how consistent enforcement is likely to be across the EU.

Supporting documentation released with the Code includes the AI Model Documentation Form and detailed Guidance for General-Purpose AI System Providers. These materials aim to help businesses understand what is expected of them under the new regime.

This is a landmark moment in the regulation of AI. Companies in the UK, EU, US and beyond must get a firm grasp of the AI systems they develop, deploy or use. From there, they need to assess how the EU AI Act, and overlapping regulatory regimes, apply to them. In most cases, this requires assembling multidisciplinary internal teams and seeking targeted legal and regulatory advice. Staying ahead of the evolving rules is no longer optional.’

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Thanks to Wayne for his thoughts on this key topic.

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You can find out more about Excello Law here.

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