Essential entities must now submit an early warning within 24 hours and a full incident report within 72 hours.
The guidance clarifies what counts as a "significant incident" and replaces the May 2025 draft that left timing ambiguous.
Action: Update your incident response runbook so the on-call lead can file an early warning to the national CSIRT within 24 hours.
Providers of GPAI models placed on the EU market will need to publish a sufficiently detailed summary of training data.
Consultation closes 30 June; SMB providers fall in scope above the 10 PFLOPs threshold.
Action: If you fine-tune or distribute foundation models, draft a training-data summary template and submit a consultation response before 30 June.
The board confirms that automated decision-making rules under Article 22 GDPR continue to apply alongside the AI Act
high-risk obligations. Joint controllership clarified for fine-tuning customer data into vendor models.
Action: Re-review your DPIAs for any AI-assisted decisions affecting customers and confirm the lawful basis still holds.
Financial entities must maintain a register at solo, sub-consolidated and consolidated level and submit it annually.
The RTS sets the exact data fields, including subcontractor chains down to the third tier.
Action: Map your current ICT third-party register against the new RTS fields; the gap is usually subcontractor depth.
Workplan published. Most products with digital elements will use self-assessment; "important" categories (II) require
a notified body. SMBs producing connected hardware should plan documentation and SBOM workflows now.
Non-binding but strongly indicative of the French CSIRT's enforcement posture. Confirms that letters of comfort
from suppliers are insufficient — contractual clauses with audit rights are now expected.
AI
Summaries are AI-generated. Always verify against the original source before acting.
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