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RAGBAZ

EU AI Act Readiness Plan — KAGP / BAZ.AI-governance

Status: compliance core complete and freeze-gated Updated: 7 July 2026 Working legal baseline: 2 August 2026 Project: BAZ.AI-governance · policy dialect glither.governance

This is an engineering readiness document, not legal advice or a conformity assessment. KAGP's role, AI-system classification, and obligations still need a deployment-specific legal and conformity review.

1. The deadline​

DateObligationHow KAGP treats it
2 Feb 2025Prohibited practices, definitions, AI literacyAlready in force
2 Aug 2025Governance and GPAI-model obligationsRelevant only if KAGP ships a model
2 Aug 2026Current AI Act baseline for high-risk obligationsBinding engineering target
2 Dec 2027Stand-alone high-risk AI systems, if the Digital Omnibus amendment enters into forceRunway, not current legal relief
2 Aug 2028High-risk AI systems embedded in regulated products, if the amendment enters into forceRunway, not current legal relief

The legal posture remains conservative. The European Parliament approved the Digital Omnibus AI amendment on 16 June 2026, including delayed application dates, but Parliament's press release says the text still requires formal Council adoption before it enters into force. Until that happens, KAGP plans to the current AI Act baseline of 2 August 2026.

2. What "meeting the deadline" means​

KAGP is aimed at the runtime articles that matter for governing AI agents:

  • Art 9 risk management through a typed policy gate
  • Art 10 data-governance controls through runtime PII scrubbing
  • Art 11 technical documentation through generated evidence exports
  • Art 12 traceability through an append-only audit chain and retention
  • Art 13 transparency through queryable audit entries
  • Art 14 human oversight through hold, review, and timeout-deny paths
  • Art 47 declaration support through a freeze-gated Annex V template
  • Art 72 post-market monitoring through replica divergence detection

The 2 August 2026 deliverable is therefore a runtime-enforced compliance core plus evidence pack, not a claim that every deployment-specific conformity assessment has been completed.

3. Completed path to the deadline​

  • Jun 30 - Jul 6 — Traceability core (Art 12, 9): event store + SHA-256 hash chain + verify-chain; glither.governance gate wired to live events.
    • PostgreSQL mutation-rejection triggers and canonical kagp-audit-v1 hashing.
    • Synchronous pre-evaluation: only allowed calls reach the upstream MCP process; hold, deny, missing audit evidence, and missing upstream configuration fail closed.
  • Jul 7 - Jul 13 — Human oversight (Art 14, 14(4), 10): authenticated review queue, SLA-timeout deny, and PII guard.
    • Reviewer identity and rationale recorded before execution.
    • Expired holds are atomically denied and audit-recorded.
    • Email and payment-card data are scrubbed from durable audit copies.
  • Jul 14 - Jul 20 — Documentation, retention, transparency (Art 11, 12(2), 13): technical-documentation export, retention/WORM, and queryable audit entries.
    • JSON and Markdown evidence exports map controls to real events and hashes.
    • Daily deterministic event segments and manifests upload to Object Lock storage with verification.
    • Bounded, filterable audit-entry pages reject invalid ranges, cursors, and page sizes.
  • Jul 21 - Jul 27 — Monitoring and conformity scaffold (Art 72, 47): divergence monitor and Declaration-of-Conformity scaffold.
    • Replica manifests are compared for signature, validity, count, base, and head divergence.
    • Annex V declaration template exports and enumerates required fields.
  • Jul 28 - Aug 1 — Evidence pack and freeze: final bundle assembly, gap sign-off, readiness statement, and manifest sealing.
    • compliance-reporter --freeze <dir> assembles the JSON report, Markdown report, Declaration of Conformity, gap sign-off sheet, readiness statement, and SHA-256 manifest.
    • The freeze gate refuses to claim readiness unless all controls are complete and required declaration fields are supplied.

4. Current compliance state (7 July 2026)​

Controls: 17/17 complete Declaration of Conformity: template complete; operator-supplied entity, signatory, place-of-issue, and standards fields are required at freeze time before a Ready verdict can be emitted. Evidence freeze: produces a Ready verdict only when all controls are complete and the declaration contains no placeholders. Verification: crate test suites pass for agent-proxy, compliance-reporter, and replica-node, including the SoftHSM2 PKCS#11 integration test.

5. Shipped hardening after the core freeze​

  • PKCS#11 / HSM signing backend in replica-node: cryptoki-backed Ed25519 signing validated end to end against SoftHSM2.
  • Email HITL channel in agent-proxy: SMTP approval requests complement the existing Discord webhook path.
  • Per-request OIDC JWT verification in agent-proxy: JWKS-backed bearer-token verification extracts subject and roles for every MCP HTTP request.
  • Observability and operations stack in agent-proxy: Prometheus metrics, JSON logs, conditional OTLP export, NATS audit fan-out, and SLA/divergence alert webhooks are implemented.

The remaining post-freeze integrations are tracked separately in the KAGP Integration Backlog.

6. Deferred to the post-deadline track​

  • full Pharo IDE polish
  • WASM/OCI packaging and deployment ergonomics
  • wider replica-fleet operations
  • notified-body and harmonised-standards work
  • EU AI Office integration details
  • deployment-specific provider/deployer classification work

7. Open decisions​

These items do not block the shipped compliance core, but they do matter for the deeper conformity track:

  1. Classification owner for each intended-purpose and value-chain role review.
  2. Conformity route and declaration process per deployment.
  3. Long-term HSM key-management model.
  4. wasi:sql versus HTTP/PostgREST boundary for longer-term component hosting.

Sources​