Proactive Engagement & Consistent Messaging

Organisations should introduce themselves to relevant competent authorities early in the compliance process, providing a brief overview of their AI portfolio, compliance approach, and contact points. This is particularly valuable in member states where the authority is newly established. Early engagement builds a constructive relationship before it is needed in a crisis.

Communication with authorities follows a consistent messaging framework: the organisation’s AI governance approach, its compliance methodology, and its contact structure are described in the same terms regardless of which authority is addressed. Inconsistent messaging across jurisdictions creates compliance risk if authorities compare notes.

Incident communication pre-defines the channel, format, signatory authority, and follow-up schedule for each jurisdiction. Routine reporting obligations (where member states require periodic compliance reporting beyond the Act’s minimum) are tracked in the jurisdiction register and submitted on schedule.

Key outputs

• Early proactive engagement with competent authorities
• Consistent messaging framework across jurisdictions
• Pre-defined incident communication protocol per jurisdiction
• Module 10 AISDP documentation

NCA Engagement Log

The NCA engagement log records every substantive interaction with competent authorities, the AI Office, and notified bodies. Each entry documents the date, the authority, the nature of the interaction (proactive introduction, consultation response, incident report, inspection, information request, sandbox participation), a summary of the discussion, any commitments made, and follow-up actions.

The log serves as the organisation’s institutional memory of regulatory interactions and as evidence of cooperative engagement. During an enforcement proceeding, the log demonstrates the organisation’s track record of constructive cooperation, which is a mitigating factor under Article 99(7).

The log is maintained by the Conformity Assessment Coordinator, with entries contributed by the AI Governance Lead, Legal and Regulatory Advisor, and any other personnel who interact with authorities. It is reviewed quarterly alongside the jurisdiction register.

Key outputs

• Per-interaction documentation (date, authority, nature, summary, commitments)
• Evidence of cooperative engagement for penalty mitigation
• Quarterly review alongside jurisdiction register
• Module 10 AISDP evidence