Lead Times by Trigger Type Lead times vary by trigger type. Planned retirement: six months or more, permitting sequential workstream execution, phased deployer transition, and thorough documentation finalisation. Voluntary compliance withdrawal: weeks to months, depending on the compliance gap severity; critical safety issues may compress to days (break-glass followed by structured withdrawal). Mandated withdrawal: 15 working days or less (authority may set a shorter timeframe), requiring parallel workstream execution and pre-prepared templates. The AI Governance Lead initiates planning as soon as a trigger is identified. For planned retirements, the planning timeline begins at T-6 months. For voluntary withdrawals, planning begins at the governance decision to withdraw. For mandated withdrawals, planning begins at the receipt of the authority’s order, and the organisation draws on pre-prepared plans. Pre-prepared end-of-life plan templates significantly reduce response time for unplanned withdrawals. The template includes the seven workstreams, pre-assigned responsibilities, and pre-drafted deployer notification text. Key outputs
- Three lead time categories (6+ months, weeks-months, 15 working days)
- Immediate planning initiation on trigger identification
- Pre-prepared templates for unplanned withdrawals
- Module 12 AISDP documentation
Stakeholder Impact Assessment Before executing any decommission activity, the AI Governance Lead assesses the impact on all stakeholders. Deployers need time to transition to alternative systems or manual processes. Affected persons whose decisions remain in effect need clarity on how those decisions will be reviewed or supported after the system is decommissioned. Internal teams that depend on the system’s outputs need replacement workflows. The stakeholder impact assessment identifies each stakeholder group, the nature and severity of the impact, the mitigation measures available, and the timeline required for those mitigations. For mandated withdrawals where the timeline is compressed, the assessment prioritises the most severely affected stakeholders (typically affected persons and deployers providing critical services). The assessment informs the deployer transition workstream and the downstream decision monitoring plan. Key outputs
- Per-stakeholder-group impact identification
- Mitigation measures and timeline requirements
- Prioritisation for compressed timelines
- Input to deployer transition and downstream monitoring
Timeline & Milestones (T-6 to T+0) The plan sets a target decommission date and works backward to define milestones for each workstream. A planned retirement follows a typical timeline: deployer announcement at T-6 months, deployer transition support beginning at T-5, new deployments blocked at T-3, inference endpoints deprecated at T-1, full shutdown at T-0, and post-decommission monitoring beginning immediately after shutdown. A mandated withdrawal compresses this into 15 working days or less. Several workstreams execute in parallel: deployer notification and technical shutdown preparations proceed simultaneously, with data lifecycle closure and documentation finalisation overlapping the shutdown itself. Each milestone has a responsible owner (from the ten organisational roles), a target date, and a completion criterion. The AI Governance Lead tracks milestone progress and escalates delays that threaten the decommission deadline. Key outputs
- Backward-planned milestones from target decommission date
- Standard timeline (T-6 to T+0) for planned retirement
- Compressed parallel execution for mandated withdrawal
- Per-milestone owner, target date, and completion criterion
Plan Governance (Prepared, Reviewed, Approved) The end-of-life plan is prepared by the AI Governance Lead, reviewed by the Legal and Regulatory Advisor (who assesses the legal implications, particularly for mandated withdrawals and Article 20 notification obligations), and approved by the appropriate governance authority. Planned retirements are approved by the AI Governance Lead. Mandated withdrawals, which may carry enforcement consequences, require executive leadership approval. The plan covers seven workstreams, each with a responsible owner, timeline, dependencies, and completion criteria. The plan itself is retained as end-of-life evidence in the AISDP. For mandated withdrawals, the plan may be prepared and approved within hours of receiving the authority’s order, drawing on the pre-prepared templates. The Legal and Regulatory Advisor’s review is expedited but not skipped; even under time pressure, the legal implications of the decommission actions must be assessed. Key outputs
- AI Governance Lead preparation, Legal review, governance approval
- Seven workstreams with owners, timelines, and dependencies
- Executive approval for mandated withdrawals
- Plan retained as AISDP evidence