C10. D&O; and Insurance Coverage Review Assessment of whether D&O; insurance covers Article 99 regulatory fines, defence costs, and personal liability for the Declaration signatory. Reviews existing policy exclusions against the Article 99 three-tier penalty framework (EUR 35M/7%, EUR 15M/3%, EUR 7.5M/1%). Findings are documented and shared with the AI Governance Lead before the Declaration is signed. Responsible party: Legal and Regulatory Advisor assesses. Regulations addressed: Article 99 (penalties); Article 47 (Declaration of Conformity, personal liability). Key outputs

• Per-tier coverage analysis
• Gap identification with recommendations