Why AI risk does not start in 2026 – but already sits in your risk register.
The EU AI Act becomes generally applicable in August 2026.
Legally correct.
From a risk perspective, dangerously misleading.
For CROs, the relevant question is not when regulation applies –
but when unmanaged AI use becomes an unquantifiable risk.
And that point is already reached in many organisations.
What has already shifted
AI systems are already:
- embedded in operational processes
- influencing decisions, scoring, prioritisation, automation
- used by business units outside formal IT or model governance
In risk terms, this means:
➡️ Material operational risk without clear ownership
➡️ Model risk without validated controls
➡️ Compliance risk without evidence
➡️ Liability exposure without governance trail
None of this starts in 2026.
Why this is a CRO issue – now
Risk committees will not ask:
“Was the EU AI Act already applicable?”
They will ask:
“Why was this risk known, but not governed?”
From an Enterprise Risk Management perspective:
- AI is already a risk driver
- Lack of governance is already a control failure
- “Waiting for regulation” is already a risk decision
The real risk gap
The real gap is not regulatory.
It is temporal.
AI adoption moves faster than:
- risk classification
- control frameworks
- auditability
- documentation
This gap is where liability crystallises.
CRO takeaway
If AI appears in your organisation before it appears in your risk framework,
you do not have an innovation problem.
You have a governance and accountability gap.
And that gap belongs on the CRO agenda now, not in 2026.