5,0/5 Google · 167 reviewsWe do not check reviews of us on other platforms that we do not quote verbatim for authenticity. They may therefore also come from people who are not our clients. The rules of the respective platform apply. Reviews that we quote verbatim on our website, by contrast, have been checked for authenticity within the meaning of Section 5b(3) UWG (German Act against Unfair Competition): we compared the reviewers’ names with our client register. We also asked the respective platform to check the reviews for authenticity.Period: October 2016 to date · As of: 28 October 2026
Implementing the AI Act in your company
Role first, then obligation.
In our experience, AI is often in use in companies faster than the legal structure behind it. We clarify the AI inventory, role, risk class and obligations, and build governance, contracts and evidence from them. We clarify your AI obligations by role and risk class and build up the evidence.
Please enter a short description first.
Initial contact is free of charge. Should any costs arise, we will inform you expressly in advance.
Response on working days within 24 hoursTo the main page on AI law
As of: 23 October 2026
AI Act check: customer service chatbot1 of 6
- System recorded in the AI inventoryAvailable
- Role: deployer or provider?Own brand, own interfaceReview
- Transparency notice under Art. 50 AI RegulationMissing in the chat windowMissing
- AI literacy of teams under Art. 4Review
- Provider contract with information rightsAudit and updates not regulatedMissing
- Approval and evidence documentedMissing
Review point: Own brand can bring you close to the provider role
- 1Record AI useSystems, providers, occasion
- 2Clarify obligationsRole, risk, obligations
- 3Set up implementationGovernance, contracts, evidence
Schematic illustration of an AI Act checklist. Simplified example.
We support AI projects for
- SaaS providers
- SMEs
- Start-ups
- Platforms
- HR tech
Key points at a glance
- The AI Act does not target AI in general, but specific systems, roles and contexts of use.
- At ITMR we clarify which AI systems are affected, whether your company is a provider, deployer or part of a supply chain, and which obligations follow.
- From this we build an obligations matrix with governance, contracts, training, transparency and evidence.
- The regulation applies in stages; the prohibitions and AI literacy under Art. 4 AI Regulation have applied since February 2025.
- Your contact is Jean Paul Bohne and his team. He is a specialist lawyer for IT law and for copyright and media law. Response on working days within 24 hours.
- KI-Verordnung
- EU regulation on artificial intelligence, also called the AI Act. It sets obligations according to risk classes.
- SaaS
- Software as a Service. Software that is used over the internet rather than installed.
- Data Act
- EU Data Regulation. It governs access to data from connected products and services.
- DSA
- Digital Services Act. EU regulation with obligations for online platforms and intermediary services.
Client moment
When does implementing the AI Act become urgent?
In our experience, AI Act implementation is rarely commissioned out of abstract interest. The pressure arises when AI is already in productive use, an AI feature is about to launch or an enterprise customer demands evidence.
At that point at the latest, a general reference to the AI Regulation is no longer enough.
Teams use tools, product areas plan AI features, sales answers enterprise questionnaires, procurement reviews providers and management wants a reliable assessment. In our mandates, often nobody internally can say for sure whether the company is a provider, deployer, integrator or part of an AI supply chain.
Many companies start with the wrong question, namely whether they fall under the AI Act at all. It is more reliable to check which AI systems are affected, which role the company takes in each set-up and which obligations arise from it.
We support companies with lawyer-led implementation. This includes an AI inventory, role clarification, risk classification, an obligations matrix, governance, contract review and an evidence structure for approval, audit, sales, due diligence and ongoing operation.
- A customer or investor asks
- Which AI systems, which role, which controls are in place?
- AI feature awaiting approval
- Product, data protection, IT security and management need a decision before the pilot or launch.
- Tool use is disorganised
- Texts, code, customer service, HR or marketing without uniform approval and without uniform evidence.
Three principles for robust implementation
A chatbot, a matching tool, a scoring module, an HR system, a copilot or a generative model can trigger completely different obligations.
In our experience, whether you are close to the role of provider, deployer, importer, distributor, product manufacturer or integrator often decides the scope of implementation.
Beyond policy texts, customers, investors, auditors and authorities ask for traceable responsibilities, approvals, controls and documents.
Brief classification before the first meeting
Briefly describe the AI use and the occasion. We will tell you which questions should be clarified first and whether an initial review or an implementation project fits.
How it works
How is the implementation plan created in three steps?
After your inquiry, we respond on working days within 24 hours.
01
Record AI use You describe AI systems, tools, product features, providers, areas of use and the occasion. This can be a launch, customer audit, management approval, procurement, enterprise sales, due diligence or internal escalation.
- Customer service chatbotown brand
- Development copilotinternal use
02
Clarify obligations We check whether your company is a provider, deployer, integrator, purchaser, distributor, importer or part of an AI supply chain, and which obligations may arise from this.
- Role
- Deployer, close to provider
- Risk
- Transparency obligation
03
Set up implementation You receive a legally structured basis for measures, responsibilities, AI governance, contract review, transparency, training, evidence and further specialist reviews.
From AI use to implementation plan in detail
- 1
Capture We record AI systems, providers, models, integrations, user groups, places of use, data flows, purposes and the business occasion in a structured way.
- 2
Assess We classify roles, risk class, proximity to prohibitions, transparency, high-risk links, GPAI questions, data protection and contract structure from a legal perspective.
- 3
Prioritise The review produces an ordered list of measures. What takes priority, what belongs in contracts, what needs to be documented, trained or technically controlled?
- 4
Implement We translate the results into a policy, approval process, contract review, responsibilities, training, evidence structure and governance.
How long does it take? Most work steps are completed within a few working days. How quickly it goes depends on the scope and on your feedback. Do you have a fixed date, such as a launch? Tell us when you send your enquiry and we will plan for it.
Implementation package
What do we build when implementing the AI Act?
Service package: implement the AI Act
AI inventory and scope Recording of relevant AI systems, models, providers, interfaces, areas of use, data flows, user groups and business purposes.
Role and risk review Classification as provider, deployer, integrator, purchaser, distributor, importer or part of a supply chain. We also check for links to prohibitions, transparency, high-risk and GPAI. With our AI Act initial check, you can narrow this down roughly in advance.
Obligations matrix Translation of the classification into concrete measures with owners, priorities, deadlines, documents, approvals, training, controls and escalation paths.
KI-Governance Setting up a practical line for tool approval, AI policy, roles, human oversight, review, monitoring, incident response and management reporting.
Contract and procurement review Review of SaaS, API, licence, development, customer service, audit, liability, data protection, indemnity and exit provisions relating to AI.
Evidence structure Material for customer questions, enterprise sales, due diligence, internal approvals, data protection review, IT security review and possible enquiries from supervisory authorities.
- For whom
- Companies that use, procure, integrate or build AI into their own products
- Service
- Initial review, obligations matrix and implementation support for the AI Act
- First response
- on working days within 24 hours
- Initial contact
- free of charge, to clarify the AI use, occasion and next step
- Costs
- We tell you expressly in advance. Only then do you decide.
- Not included in the package
- Technical conformity assessment, certification and proceedings before authorities. This is a separate service, on request and as needed.
Who delivers what and who decides
- Tool list and product description
- Provider documents and draft contracts
- Data flow overview, use cases and user groups
- Existing approval process, data protection and security documents
- Specific questions from customers, auditors or investors
- Role and risk classification
- Obligations matrix with priorities
- Governance, policy and approval process
- Review of AI contracts
- Your management on approval and resources
- Supervisory authorities on interpretation in the individual case
How does the engagement work?
- 1
Initial assessment We review your information and tell you whether the package fits or another route makes more sense.
- 2
Offer for the package If the package fits, you receive an offer for classification, an overview of obligations and an implementation plan. We only start after your approval.
- 3
Court action agreed separately Proceedings before authorities or courts and representation in them are not part of the package. We agree these steps separately.
Role clarification
Are you a provider, deployer or integrator?
A company can touch several roles in one AI project. It procures a tool, integrates it into its own processes, changes the purpose of use, markets an AI feature or provides a solution to customers.
| Set-up | Typical company question | Relevance for implementation |
|---|---|---|
| Internal AI use | May teams use an AI tool for texts, code, research, customer service, marketing or analysis? | AI literacy, usage rules, data protection, protection of secrets, output control, approval process and documentation. |
| AI tool in procurement | Can an external provider be integrated into existing processes, customer data, SaaS systems or internal workflows? | Provider information, contract clauses, allocation of roles, data flows, audit rights, security requirements and exit scenario. |
| AI feature in your own product | Does an integration become your own AI function under your own brand, interface or purpose? | Distinguishing provider and deployer, technical documentation, transparency, liability, product communication, monitoring and change management. |
| Proximity to high risk | Does the system affect employment, education, critical infrastructure, access to services, health, safety or fundamental rights? | In-depth classification, human oversight, data quality, logging, risk management, information obligations and possible conformity requirements. |
| GPAI and model link | Is a general-purpose AI model used, adapted, integrated, passed on or used as the basis for downstream systems? | Model information, supply chain communication, technical documents, copyright policy, usage limits and contractual information flows. |
Put simply, providers place an AI system on the market under their own responsibility, and deployers use it under their own responsibility. Adaptation, integration or your own brand can shift the boundary.
Timeline, subject to updates
When do the obligations of the AI Regulation apply?
For companies, what counts besides the date in the law is what customers, investors, supervisors, procurement and management expect. The EU adopted the postponement of the high-risk rules with the Digital Omnibus (Regulation (EU) 2026/1744, in force since 27 July 2026): Annex III applies from 2 December 2027, Annex I from 2 August 2028.
| Criterion | Status | What companies should do now |
|---|---|---|
| Prohibitions and AI literacy | Prohibitions have applied since 2 February 2025. AI literacy (Art. 4, as amended by Regulation (EU) 2026/1744): measures to promote AI literacy, enforcement from 2 August 2026 | Check which AI use may be prohibited and how teams are sufficiently enabled |
| GPAI and governance | have applied since 2 August 2025 | Clarify model integration, supply chain, information and documentation |
| Broader application | from 2 August 2026 (Art. 50 for existing systems: from 2 December 2026) | Prepare transparency, risk classification, deployer obligations and evidence |
| High-risk deadlines | Annex III from 2 December 2027, Annex I from 2 August 2028 (Digital Omnibus, Regulation (EU) 2026/1744) | Do not postpone role clarification, product decisions and contract structure |
In practice, what counts is whether an AI use must be approved, sold, procured, audited or explained to third parties today. The deadlines reflect the status as of 26 October 2026. Updated on 26 October 2026: deadlines adjusted to the Digital Omnibus (Regulation (EU) 2026/1744).
Decision questions
What must be clarified before approving AI?
A legally robust AI approval is not a simple yes-or-no decision. It must explain what is being approved, under which conditions use is permitted and which controls apply in operation.
Four questions for every approval
- What is the system? Tool, model, product feature, API, recommender system, decision support, generative function or automated process?
Who is responsible for what? Provider, deployer, business unit, procurement, IT, data protection, product team, management, service provider or customer?Which risks arise? Fundamental rights, employees, customers, sensitive data, discrimination, safety, transparency, IP, trade secrets or liability?What evidence remains? Inventory, approval, policy, training, contract, technical documentation, control concept, review note, management decision or audit package?
With our AI Act initial check, you can roughly narrow down in advance whether your system is likely to be classified as high-risk AI, a GPAI application or a system subject to transparency obligations.
Typical occasions
In which situations do we support AI Act projects?
Starting points vary widely. The legal core remains the same: system, role, risk, obligation and evidence.
Customer service chatbot A company uses a chatbot under its own brand. We review the transparency notice, the role towards the model provider, data flows, escalation to humans and the evidence for customer questions.
AI in recruiting An HR tool pre-sorts applications. We review proximity to high risk, human oversight, information of employee representatives, data protection and the obligations as deployer.
AI feature in a SaaS product A software provider integrates a language model into its product. We clarify the provider role, documentation, customer contracts, usage limits and communication with the model provider.
Enterprise questionnaire A major customer requests information on AI systems, controls and training. We build a robust line of answers that also holds up in later audits and contract negotiations.
Due diligence Investors review AI risks before a funding round or transaction. We prepare the inventory, role clarification, contracts and governance so that questions can be answered in a traceable way.
Outcome
What is more robust after implementation?
The goal is not abstract completeness, but a basis for decisions on operation, approval, contracts, sales, audits and management.
AI systems, roles, risk classes, obligations, priorities, deadlines, owners and evidence are linked in a traceable way.
You can better judge when you are merely using a tool and when integration, distribution, adaptation or your own purpose trigger further obligations.
Approvals, training, responsibilities, human oversight, review, monitoring, escalation and management decisions work together.
AI providers, service providers, development partners and customers are bound in with clearer rules on information, audit, data protection, liability, security and updates.
The AI Act does not require a general AI officer modelled on a data protection officer. A responsible AI governance function can make sense. What matters are responsibilities, competence, approvals, control and evidence.
Official guidance
Which official sources apply to the AI Act?
For robust implementation, we work with official sources and monitor current legislative changes. Secondary knowledge does not replace a specific review of roles, risks and contracts.
Regulation (EU) 2024/1689 governs roles, risk classes, obligations, transparency, general-purpose AI models and penalties. Art. 4 requires AI literacy, Art. 5 contains the prohibitions and Art. 50 the transparency obligations, for example for chatbots.
- AI Regulation (EU) 2024/1689 on EUR-Lex Official text for roles, risk classes, obligations, transparency, GPAI and penalties.
- European Commission on the AI Act Application timetable, AI Office, governance, guidelines and implementation instruments.
- European Commission on the GPAI Code of Practice Guidance for general-purpose AI models and their supply chain.
- Federal Network Agency on the AI Regulation National reference point on risk levels, AI literacy, high risk and market surveillance.
Sources of error
Why does AI Act implementation fail?
In our experience, knowledge is rarely what is missing. What is missing is the connection between IT, procurement, legal and the business unit.
- 1
Broader AI questions For liability, copyright, data protection and product strategy in AI projects, AI law is the broader route.
- 2
Several digital acts If the Data Act, DSA, NIS2, CRA or DMA must be reviewed together with the AI Act, the EU Digital Acts Audit is the next step.
- 3
Chatbots with minors If a chatbot also reaches children, today mainly Art. 50(1) and Art. 5(1)(b) AI Regulation apply. The proposed EU KIDS Act would bring further obligations, but it has not yet been adopted.
Typical mistakes in implementation
- The AI list comes from IT, the contracts from procurement, the data protection review from legal and the product reality from the business unit. Nobody brings them together.
- A company considers itself a mere user, although integration, configuration, distribution or its own purpose move it closer to provider obligations.
- AI literacy is treated as standard training without taking account of roles, risks, contexts of use and the people affected.
- Proximity to high risk is only checked shortly before launch, although product design, data quality, control and documentation must be planned early.
- Contracts with AI providers contain no robust rules on information, audit, updates, liability, data protection, security or exit.
- Transparency obligations are treated as a UX copy problem, although they belong in product design, process, communication and documentation.
- GPAI and model questions are overlooked, although downstream information, usage limits and supply chain communication can be decisive.
- Evidence is only created when a customer, investor, auditor or supervisor asks for it. By then the approval history, responsibilities and documentation trail are missing.
Your contact
Lawyer and mediator · Partner · Specialist lawyer for IT law · Specialist lawyer for copyright and media law
View profile Düsseldorf, Schirmerstraße 80 · Hamburg, Palmaille 124
TOP Lawyer 2027 · Business lawyers · Intellectual property
F.A.Z.-Institut and QuantiQuest. Based on recommendations from fellow lawyers and assessments by in-house counsel. Source (opens in a new tab)
ReviewsWe do not check reviews of us on other platforms that we do not quote verbatim for authenticity. They may therefore also come from people who are not our clients. The rules of the respective platform apply. Reviews that we quote verbatim on our website, by contrast, have been checked for authenticity within the meaning of Section 5b(3) UWG (German Act against Unfair Competition): we compared the reviewers’ names with our client register. We also asked the respective platform to check the reviews for authenticity.
What clients say
5,0 von 5 · 71 Bewertungen auf anwalt.dePeriod: October 2018 to date · As of: 28 October 2026
“Actually, 5 stars is still too few, and I never usually write things like this. I contacted the firm today because I wanted brief advice on an incident. I was then referred to Mr Bohne. Mr Bohne asked me to describe my exact concern by email. …” (translated from German)
“The advice was very competent and professional. I am very happy to recommend Mr Bohne and would come back to him at any time.” (translated from German)
“Mr Bohne answered all relevant questions in the very first meeting. Thank you!” (translated from German)
FAQ
Frequently asked questions on implementing the AI Act
Does every company that uses AI need to start a large AI Act project?
No. The scope depends on the role, system, context of use, risk and business occasion. A structured initial review makes sense: which AI systems exist, who uses them, what role does the company have and which evidence is needed?
We summarise which deadlines the Digital Omnibus postponed in our article (in German) Digital Omnibus on AI .
Is an AI policy enough to implement the AI Regulation?
An AI policy can help, but it does not replace clarifying roles, risk classification, contract review, tool approval, training, documentation and control. It should be part of robust AI governance.
Does a company need an AI officer?
The AI Act does not require a general AI officer in the way data protection law requires a data protection officer. A responsible internal or external AI governance function can still make sense if responsibilities, approvals, training and evidence would otherwise not be reliably organised.
What is the difference between a provider and a deployer?
Put simply, providers place an AI system or a general-purpose AI model on the market or put it into service under their own responsibility. Deployers use an AI system under their own responsibility. It becomes difficult when a company adapts, integrates, markets or provides systems under its own brand.
When does high-risk AI need particular scrutiny?
When AI is used in areas such as employment, education, critical infrastructure, access to services, safety, health, biometric applications or decisions affecting fundamental rights.
Which documents help with an initial AI Act review?
Helpful are a tool list, product description, provider documents, draft contracts, a data flow overview, use cases, user groups, the approval process, data protection documents, security requirements and specific questions from customers, auditors or investors.
What should be reviewed in contracts with AI providers?
Important points are roles, the service description, information obligations, technical changes, data protection, protection of trade secrets, training data, subcontractors, security, audit rights, liability, indemnity, use of output, availability and exit.
When should we involve you early?
Before a product launch, tool rollout, enterprise sale, customer audit or due diligence, and before introducing AI in HR or sensitive decision-making processes. Early support also makes sense if the provider or deployer role is unclear.
Do special rules apply to chatbots that children also use?
Today, mainly the AI Regulation. Users must be told that they are talking to an AI (Art. 50(1) AI Regulation). AI that exploits age-related vulnerabilities and can thereby cause significant harm is prohibited (Art. 5(1)(b) AI Regulation).
Next step
Clarify AI Act obligations before audits set the pace
If AI is already in use, an AI feature is awaiting approval or external stakeholders demand evidence, implementation should not stop at a general assessment. We recommend a line consisting of an AI inventory, role clarification, an obligations matrix, governance, contracts and evidence.
Helpful for the initial classification
- Tool list or AI inventory, even if incomplete
- Product description of the AI feature
- Provider documents and draft contracts
- Data flow overview and user groups
- Specific questions from customers, auditors or investors
An incomplete list is enough to start. We will work out the rest together.
Have your AI use and obligations reviewed
Briefly describe the AI use, the occasion and your role in the project.
Helpful are a tool list, product description, provider documents and specific customer questions.
Related services
KI-Recht Broader classification of AI projects, liability, data protection, copyright and product strategy.AI-Act-Erstcheck Rough preliminary classification of risk class and obligations.IT contract / software contract When AI needs to be covered in SaaS, API, licence, development, SLA or exit provisions.Data protection law When legal bases, DPIA, DPA, transparency or third-country transfers are the focus.Data law When training data, data access, the Data Act or data licensing are decisive.EU Digital Acts Audit When the AI Act, Data Act, DSA, NIS2, CRA or DMA are reviewed together.IT law & digitalisation When it is still open which practice area is the focus.KI-Compliance Secure your own AI tools.Implement the Data Act Data access and contracts.
From our blog: AI literacy under Art. 4 · Overview of typical AI use cases · Digital Omnibus on AI · Transparency obligations under Art. 50
