From Policy to Practice: Prototyping the EU AI Act's Human Oversight Requirements

40 Pages Posted: 30 Apr 2025

See all articles by Wannes Ooms

Wannes Ooms

KU Leuven - Centre for IT & IP Law (CiTiP)

Lotte Cools

affiliation not provided to SSRN

Thomas Gils

KU Leuven - Centre for IT & IP Law (CiTiP)

Frederic Heymans

Interuniversity MicroElectronics Center - IMEC - SMIT, Vrije Universiteit Brussel

Date Written: March 27, 2025

Abstract

Article 14 AI Act mandates that high-risk AI systems are designed and developed in such a way that they enable effective human oversight. It establishes the requirement that human oversight be made possible by providers both through the design of the high-risk AI system as well as through organisational measures, identified by the provider and implemented by the deployer. This should ensure that the risks to health, safety and fundamental rights are effectively mitigated. 

This project intended to test the human oversight requirements for high-risk AI systems in the AI Act by gathering stakeholders to implement these requirements into prototype compliance documents. We collected feedback on these prototype compliance documents in order to determine best practices and policy recommendations. This report includes the compliance documents drafted by the participants of the policy prototyping workshop in its annex. In addition, the report also features reviewer feedback on those documents and the human oversight requirement contained in article 14 AI Act.

Keywords: AI Act, Human oversight, high-risk AI systems, policy prototyping, product safety, law enforcement, AI in education, AI in healthcare, Artificial Intelligence, AI governance, compliance, AI regulation

Suggested Citation

Ooms, Wannes and Cools, Lotte and Gils, Thomas and Heymans, Frederic, From Policy to Practice: Prototyping the EU AI Act's Human Oversight Requirements (March 27, 2025). Available at SSRN: https://ssrn.com/abstract=5196091 or http://dx.doi.org/10.2139/ssrn.5196091

Wannes Ooms

KU Leuven - Centre for IT & IP Law (CiTiP) ( email )

Lotte Cools

affiliation not provided to SSRN

Thomas Gils (Contact Author)

KU Leuven - Centre for IT & IP Law (CiTiP) ( email )

Sint-Michielsstraat 6 box 3443
Leuven, 3000
Belgium

Frederic Heymans

Interuniversity MicroElectronics Center - IMEC - SMIT, Vrije Universiteit Brussel ( email )

Pleinlaan 9
Brussels, 1050
Belgium

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