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  / SOC 2 to ISO 27001 Mapping: A Crosswalk Guide

SOC 2 to ISO 27001 Mapping: A Crosswalk Guide

A company that already holds a SOC 2 report has, by most industry estimates, already built somewhere between 60 and 80 percent of what ISO 27001 certification requires. Yet only a small fraction of organizations actually capture that overlap. Teams run the second framework as a fresh project, rewrite policies that already exist, and re-collect evidence they already have on file. The result is paying twice for the same security program.

SOC 2 to ISO 27001 mapping is the discipline that stops this. It is a control crosswalk: a structured comparison that shows which SOC 2 controls already satisfy which ISO 27001 requirements, where the genuine gaps sit, and what new work the second framework actually demands. Done well, it turns the second audit from a rebuild into a mapping exercise.

SOC 2 to ISO 27001 Mapping

What Is SOC 2 to ISO 27001 Mapping?

SOC 2 to ISO 27001 mapping links each SOC 2 Trust Services Criterion to its corresponding ISO 27001 clause or Annex A control. The output is a single control library: each control is defined once, tagged to both frameworks, and backed by evidence that both auditors will accept.

Worth being clear about upfront: a crosswalk does not make you compliant with anything. It shows where coverage already exists and where it does not. The real work still sits in control design, evidence discipline, and keeping the mapping current as systems and vendors change.

A spreadsheet built once and never touched again becomes an audit liability, not an asset. For a structured starting point, a thorough SOC 2 to ISO 27001 gap analysis will surface those liabilities before an auditor does.

 

SOC 2 Trust Services Criteria: An Overview

SOC 2 is an attestation framework from the American Institute of Certified Public Accountants (AICPA). It is built on five Trust Services Categories: Security, Availability, Processing Integrity, Confidentiality, and Privacy. Security is the only mandatory category, and every SOC 2 report includes it.

The Security category is evaluated through the Common Criteria, written as CC1 through CC9, containing 32 individual criteria in total. CC1 through CC5 cover the control environment, communication, risk assessment, monitoring, and control activities, and they align directly with the COSO internal control framework. CC6 through CC9 are more technology-specific, covering logical and physical access, system operations, change management, and risk mitigation.

A SOC 2 audit produces one of two report types. A Type 1 report assesses control design at a single point in time. A Type 2 report assesses both design and operating effectiveness across an observation window, usually 3 to 12 months. A licensed CPA firm issues the report. SOC 2 is an attestation, not a certification, and there is no such thing as a SOC 2 certificate.

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ISO 27001 Annex A Controls: An Overview

ISO/IEC 27001 is the international standard for an information security management system, or ISMS. The current version, ISO 27001:2022, has two distinct layers, and the distinction matters for any mapping effort.

Clauses 4 through 10 define the management system itself: organizational context, leadership, planning, risk treatment, support, operations, performance evaluation, and improvement. These clauses are mandatory. Annex A is the second layer, a reference catalogue of 93 controls grouped into four themes: Organizational (37 controls), People (8), Physical (14), and Technological (34). The 2022 revision consolidated the previous 114 controls and 14 domains and added 11 new controls covering areas such as threat intelligence and cloud security.

Annex A controls are not all mandatory. Organizations select controls based on a risk assessment and record their choices, including any exclusions and the reasoning behind them, in a Statement of Applicability. Certification is granted by an accredited body, lasts three years, and requires annual surveillance audits. Learn more about what the full certification process involves.

 

Key Structural Differences That Affect Mapping

The two frameworks share a large security foundation, but they are built differently, and a mapping that ignores the structural gaps will fail. Understanding ISO 27001 vs SOC 2 at a structural level is the prerequisite for any mapping work worth doing. Four differences matter most.

ISO 27001 certifies a management system, while SOC 2 attests to a set of controls. ISO Clauses 4 through 10 have no direct SOC 2 equivalent, because SOC 2 never asks you to prove you run a continuous, governed program; it asks only whether specific controls met specific criteria during the review period.

Scope differs too. An ISO 27001 ISMS is expected to cover the organization broadly, while SOC 2 scope is set at the level of a system or service. The outputs differ as well: ISO produces a pass or fail certificate, whereas a SOC 2 report can carry noted exceptions or a qualified opinion and still be a valid, useful report. And because SOC 2 Type 2 tests evidence across a defined window, a control that worked only on audit day will not pass.

The most common mapping mistake is treating ISO 27001 as SOC 2 plus a few extra controls. It is not.

The Annex A controls map cleanly, but the ISMS management clauses, including internal audit, management review, and continual improvement, are a separate body of work with no SOC 2 starting point. Budget for them as net-new.

 

SOC 2 Common Criteria to ISO 27001 Control Mapping

The Common Criteria map to ISO 27001 with a high degree of overlap. The table below is a practical starting crosswalk for the CC series. It lists the primary ISO 27001 references rather than every possible match, and your auditor’s judgment will shape the final mapping.

SOC 2 Common Criteria

Topic

Primary ISO 27001:2022 References

CC1

Control Environment

Clauses 5 (Leadership), 6 (Planning), A.5.1, A.5.2, A.6.1–A.6.4

CC2

Communication and Information

Clause 7.4 (Communication), A.5.1, A.6.3, A.8.2

CC3

Risk Assessment

Clause 6.1 (Risk Assessment), A.5.7, A.8.8

CC4

Monitoring Activities

Clause 9 (Performance Evaluation), A.5.35, A.5.36, A.8.16

CC5

Control Activities

Clause 6.1.3 (Risk Treatment), A.5.37, A.8.9

CC6

Logical and Physical Access

A.5.15–A.5.18, A.5.31, A.7.1–A.7.4, A.8.2–A.8.5, A.8.18

CC7

System Operations and Incident Response

A.5.24–A.5.28, A.8.15, A.8.16

CC8

Change Management

A.8.32

CC9

Risk Mitigation and Vendor Management

A.5.19–A.5.23, A.6.7, A.8.30

The AICPA publishes an official mapping of the Trust Services Criteria to ISO 27001, and it is a reasonable reference point. Treat any published crosswalk as a draft, though. No mapping survives contact with a real environment unchanged, because how a control is tested depends on how your organization actually operates it.

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SOC 2 Additional Categories Mapped to ISO 27001

If your SOC 2 scope includes categories beyond Security, those map to Annex A as well, though less tidily than the Common Criteria do.

Availability lines up with the ISO controls for backup (A.8.13), redundancy (A.8.14), capacity management (A.8.6), and ICT readiness for business continuity (A.5.30).

Confidentiality maps to information classification (A.5.12), labelling (A.5.13), cryptography (A.8.24), and information deletion (A.8.10).

Processing Integrity is the weakest fit. It relates loosely to the secure development controls A.8.25 through A.8.29, but ISO 27001 has no control dedicated to transaction completeness and accuracy, as SOC 2 does.

Privacy maps partially to A.5.34, which covers privacy and protection of personally identifiable information, but the genuine counterpart is ISO/IEC 27701, the privacy extension to ISO 27001. Organizations serious about privacy assurance usually pursue 27701 alongside the base certification rather than leaning on a single Annex A control.

 

Control Areas With Strong Overlap Between SOC 2 and ISO 27001

Several domains map so cleanly that one well-designed control satisfies both frameworks at once, and these are the areas where a dual-framework program pays for itself fastest.

Access control is the clearest case.

SOC 2’s CC6 and ISO’s A.5.15 through A.8.5 cover the same ground: least privilege, multi-factor authentication, access reviews, and credential management. A single access control policy and one quarterly review process will serve both audits. Incident response overlaps just as well, with CC7 aligning to ISO’s A.5.24 through A.5.28, so one incident response plan with defined roles and tested playbooks covers both frameworks simultaneously.

Change management maps CC8 to A.8.32.

Vendor and third-party risk maps CC9 to the supplier controls in A.5.19 through A.5.23. Data backup and recovery maps the Availability criteria to A.8.13 and A.8.14. Physical security maps the physical elements of CC6 to the A.7 control family. In each of these areas, the work is to design the control once and produce evidence that both auditors will accept.

Pro Tip: Two frameworks with Different Frequencies

Where the two frameworks set different frequencies for the same control, default to the stricter one. If ISO 27001 expects quarterly access reviews and your SOC 2 controls only specified annual reviews, run them quarterly. One piece of evidence then satisfies both auditors, and you never have to explain a mismatch in a control narrative.

Control Gaps: Where SOC 2 and ISO 27001 Diverge

Controls Unique to ISO 27001 Not Covered by SOC 2

The biggest gap is the management system itself. ISO 27001 Clauses 4 through 10 require a documented ISMS scope, a formal risk treatment plan, an internal audit program, a management review process, and a continual improvement cycle based on Plan-Do-Check-Act. SOC 2 touches none of this directly.

The Statement of Applicability has no SOC 2 equivalent, and neither does the formal tracking of nonconformities. For a team arriving from SOC 2, this management layer is where most of the genuine new effort goes.

SOC 2 Requirements Not Addressed by ISO 27001

The gap runs in the other direction, too. SOC 2 evaluates controls against the system commitments described in the report, and a Type 2 engagement tests evidence across a continuous observation window. ISO 27001 has no comparable concept of a multi-month evidence period or a detailed, customer-facing report that describes your system.

SOC 2’s point-of-focus testing is also more granular in places, and its Processing Integrity category has no clean ISO home. An ISO certificate, on its own, does not produce the detailed control narrative that US enterprise buyers often expect to review.

 

Why Map SOC 2 Controls to ISO 27001?

The case for mapping comes down to three concrete returns, and they compound over time.

It reduces audit fatigue and overhead. Teams that build a unified control set and map it to both frameworks consistently spend far less on the second framework than teams running two separate projects. One policy library, one evidence cadence, and one remediation backlog replace two of everything.

A well-maintained SOC 2 compliance checklist that is also cross-referenced against ISO requirements is a practical way to keep that single-source discipline in place day to day.

It strengthens your security posture. Mapping forces you to reconcile two views of the same risks. SOC 2 frames controls around service commitments, while ISO 27001 frames them around information assets and a formal risk assessment. Reconciling the two surfaces gaps that either framework alone would miss, and gaps that auditors and attackers both find.

It meets multiple market requirements at once. US enterprise buyers generally expect SOC 2. European and international customers, along with a growing number of large procurement teams, expect ISO 27001. Microsoft, for one, stopped accepting SOC 2 security reports as sufficient evidence for its supplier program after 2021. Holding both removes the framework question from your sales cycle entirely.

SOC 2 to ISO 27001 Gap Analysis

How to Conduct a SOC 2 to ISO 27001 Gap Analysis

Step 1: Inventory Existing SOC 2 Controls

Start with a complete list of the controls already operating under your SOC 2 program, each recorded with its owner, its frequency, and the evidence it produces. This inventory is the raw material for everything that follows, so it needs to reflect reality rather than the control descriptions in last year’s report. Controls that exist on paper but are not actually being operated will fail ISO testing just as quickly as they would fail a SOC 2 Type 2 review.

Step 2: Align Risk Assessment Processes Across Both Frameworks

SOC 2 expects risks to be assessed and mitigated. ISO 27001 goes further, requiring a documented, repeatable risk assessment methodology and a risk treatment plan tied to the Statement of Applicability. The practical answer is to run one unified risk assessment in a single register that addresses both threats to information assets and risks to your service criteria, rather than maintaining two registers that inevitably drift out of sync.

Step 3: Identify Overlapping and Conflicting Documentation

Compare policies side by side. Where two documents cover the same ground, consolidate them into one. Where they conflict, whether on review frequencies, definitions, or scope, resolve the conflict before an auditor finds it. Conflicting documentation is one of the fastest ways to draw a finding, because it raises the obvious question of which version staff are actually following.

Step 4: Address Scoping Misalignments

SOC 2 scope is set at the system level, while an ISO 27001 ISMS is expected to be broader. Decide deliberately what the ISMS covers and confirm it is consistent with what your SOC 2 report describes. Mismatched scope is one of the most heavily scrutinized issues in an ISO certification audit, and it is also one of the common pitfalls that derails otherwise well-prepared teams.

Step 5: Build a Unified Control Set

Produce a single control catalogue in which each control is defined once, mapped to both frameworks, assigned an owner, and written at a level that stays stable as systems change. This catalogue, not the original mapping spreadsheet, is the durable output of the whole exercise. Everything else feeds into it and is governed by it going forward.

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Best Practices for Successful SOC 2 to ISO 27001 Mapping

Use a Unified Control Framework as Your Foundation

Define each control once, map it to both frameworks, and treat that catalogue as the single source of truth. Separate per-framework spreadsheets drift apart within a quarter, and reconciling them later costs more in time and rework than building the unified version correctly from the start. Reference frameworks like NIST CSF can serve as a neutral backbone that maps to both SOC 2 and ISO 27001, which is particularly useful for organizations that anticipate adding more frameworks in the future.

Automate Compliance Audits Where Possible

Manually collecting and tagging the same evidence for two audits is where both time and accuracy leak. Tag each piece of evidence with every control it supports, across both frameworks, so it is collected once and reused. Automated, time-stamped evidence is also more convincing to an auditor than a manually assembled folder.

Automate compliance audits using purpose-built tools and you eliminate a category of error that manual processes cannot reliably prevent. Pair automation with continuous monitoring and your evidence library stays current between audits rather than being assembled in a panic the week before fieldwork begins.

Regularly Update Your Mapping as Standards Evolve

Frameworks change, as the 2022 ISO revision demonstrated, and so do your systems and vendors. Review the crosswalk on a schedule and whenever you add a system, adopt a new cloud service, or change a core process.

A mapping left static between audits tends to be quietly wrong by the time anyone needs it, and the auditor will find the discrepancies before you do.

Involve Cross-Functional Stakeholders in the Mapping Process

Mapping is not a job for one compliance manager working alone. Control owners in engineering, IT, human resources, and legal need to confirm that the mapped controls reflect how work actually happens. A crosswalk owned by one person and never seen by the people who run the controls is the version auditors quietly take apart. The people closest to the systems know where the documentation does not match the practice, and that knowledge needs to be in the crosswalk before the audit, not discovered during it.

Common Pitfalls When Mapping SOC 2 to ISO 27001

Scoping misalignment is the most frequent failure. A narrow SOC 2 system boundary quietly becomes the assumed ISMS scope, and the ISO auditor pushes back hard.

Duplicate and conflicting documentation is close behind: two access policies, two incident response plans, slightly different in wording and both technically in force, with no clear authority on which one governs.

Overlooking third-party risk catches teams that treated vendor management lightly under SOC 2, since ISO’s supplier controls in A.5.19 through A.5.23 expect a more structured and documented program. And many teams fail to account for the continual improvement obligation, mapping the Annex A controls cleanly while forgetting that ISO’s internal audit and management review requirements are ongoing rather than one-time tasks.

Reviewing the full list of common pitfalls before you start the mapping effort is time well spent.

Auditors test evidence, not intent. A flawless crosswalk spreadsheet proves nothing on its own. What an ISO 27001 auditor wants to see is the management review minutes, the internal audit reports, and the nonconformity log, artifacts that only exist if the ISMS has actually been running for a few months. Start those processes early, well before you feel ready, so the evidence trail exists when the audit arrives.

Frequently Asked Questions

Does SOC 2 to ISO 27001 mapping guarantee compliance with both frameworks?

No. Mapping shows where control coverage overlaps and where gaps remain. Compliance still depends on designing the controls properly, operating them consistently, and producing evidence that satisfies each auditor. A crosswalk is a planning tool, not a substitute for the work itself.

Industry estimates generally place the control overlap between 60 and 80 percent, concentrated in access control, risk management, incident response, and change management.

The overlap is high enough that the second framework should never be a full rebuild, but it is not complete, because the ISO management system clauses have no SOC 2 equivalent and must be built from scratch regardless of where you are starting from.

Often, yes. A large share of SOC 2 evidence, including access reviews, change tickets, vulnerability scans, and training records, directly supports ISO 27001 Annex A controls.

The catch is that ISO also requires evidence SOC 2 never asks for, such as internal audit reports and management review records, which must be generated separately and cannot be substituted.

Treat it as a living document. Review it at least once a year, and also whenever you add a major system, adopt a new cloud service, change a core process, or when either framework is revised. A mapping that sits untouched between audits is almost certainly inaccurate by the time it is needed.

It depends on your customers. If your buyers are mostly US-based, starting with SOC 2 is common practice. If you sell internationally or need a recognized certificate, starting with ISO 27001 builds the broader management system foundation and tends to make the subsequent SOC 2 faster. Either order works.

What matters is building one security program rather than two. A good SOC 2 guide can help you assess which starting point makes the most sense for your current market and customer base.

For most organizations, ISO 27001 takes more time and effort on the first attempt, mainly because of the management system requirements. SOC 2 has no equivalent to the ISMS clauses, the Statement of Applicability, or the internal audit and management review cycle.

The controls themselves are comparable in difficulty. It is the surrounding management system that makes ISO 27001 the heavier lift, and the reason why arriving from SOC 2, with your control library already built, gives you a meaningful head start.

Axipro Author

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Pedro Dias

Pedro has been writing online for over 10 years. With experience in all things programming, cyber security, and compliance, he is our editor-in-chief at Axipro.

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The output is a single control library: each control is defined once, tagged to both frameworks, and backed by evidence that both auditors will accept. Worth being clear about upfront: a crosswalk does not make you compliant with anything. It shows where coverage already exists and where it does not. The real work still sits in control design, evidence discipline, and keeping the mapping current as systems and vendors change. A spreadsheet built once and never touched again becomes an audit liability, not an asset. For a structured starting point, a thorough SOC 2 to ISO 27001 gap analysis will surface those liabilities before an auditor does.   SOC 2 Trust Services Criteria: An Overview SOC 2 is an attestation framework from the American Institute of Certified Public Accountants (AICPA). It is built on five Trust Services Categories: Security, Availability, Processing Integrity, Confidentiality, and Privacy. Security is the only mandatory category, and every SOC 2 report includes it. The Security category is evaluated through the Common Criteria, written as CC1 through CC9, containing 32 individual criteria in total. CC1 through CC5 cover the control environment, communication, risk assessment, monitoring, and control activities, and they align directly with the COSO internal control framework. CC6 through CC9 are more technology-specific, covering logical and physical access, system operations, change management, and risk mitigation. A SOC 2 audit produces one of two report types. A Type 1 report assesses control design at a single point in time. A Type 2 report assesses both design and operating effectiveness across an observation window, usually 3 to 12 months. A licensed CPA firm issues the report. SOC 2 is an attestation, not a certification, and there is no such thing as a SOC 2 certificate. ISO 27001 Annex A Controls: An Overview ISO/IEC 27001 is the international standard for an information security management system, or ISMS. The current version, ISO 27001:2022, has two distinct layers, and the distinction matters for any mapping effort. Clauses 4 through 10 define the management system itself: organizational context, leadership, planning, risk treatment, support, operations, performance evaluation, and improvement. These clauses are mandatory. Annex A is the second layer, a reference catalogue of 93 controls grouped into four themes: Organizational (37 controls), People (8), Physical (14), and Technological (34). The 2022 revision consolidated the previous 114 controls and 14 domains and added 11 new controls covering areas such as threat intelligence and cloud security. Annex A controls are not all mandatory. Organizations select controls based on a risk assessment and record their choices, including any exclusions and the reasoning behind them, in a Statement of Applicability. Certification is granted by an accredited body, lasts three years, and requires annual surveillance audits. Learn more about what the full certification process involves.   Key Structural Differences That Affect Mapping The two frameworks share a large security foundation, but they are built differently, and a mapping that ignores the structural gaps will fail. Understanding ISO 27001 vs SOC 2 at a structural level is the prerequisite for any mapping work worth doing. Four differences matter most. ISO 27001 certifies a management system, while SOC 2 attests to a set of controls. ISO Clauses 4 through 10 have no direct SOC 2 equivalent, because SOC 2 never asks you to prove you run a continuous, governed program; it asks only whether specific controls met specific criteria during the review period. Scope differs too. An ISO 27001 ISMS is expected to cover the organization broadly, while SOC 2 scope is set at the level of a system or service. The outputs differ as well: ISO produces a pass or fail certificate, whereas a SOC 2 report can carry noted exceptions or a qualified opinion and still be a valid, useful report. And because SOC 2 Type 2 tests evidence across a defined window, a control that worked only on audit day will not pass. The most common mapping mistake is treating ISO 27001 as SOC 2 plus a few extra controls. It is not. The Annex A controls map cleanly, but the ISMS management clauses, including internal audit, management review, and continual improvement, are a separate body of work with no SOC 2 starting point. Budget for them as net-new.   SOC 2 Common Criteria to ISO 27001 Control Mapping The Common Criteria map to ISO 27001 with a high degree of overlap. The table below is a practical starting crosswalk for the CC series. It lists the primary ISO 27001 references rather than every possible match, and your auditor’s judgment will shape the final mapping. SOC 2 Common Criteria Topic Primary ISO 27001:2022 References CC1 Control Environment Clauses 5 (Leadership), 6 (Planning), A.5.1, A.5.2, A.6.1–A.6.4 CC2 Communication and Information Clause 7.4 (Communication), A.5.1, A.6.3, A.8.2 CC3 Risk Assessment Clause 6.1 (Risk Assessment), A.5.7, A.8.8 CC4 Monitoring Activities Clause 9 (Performance Evaluation), A.5.35, A.5.36, A.8.16 CC5 Control Activities Clause 6.1.3 (Risk Treatment), A.5.37, A.8.9 CC6 Logical and Physical Access A.5.15–A.5.18, A.5.31, A.7.1–A.7.4, A.8.2–A.8.5, A.8.18 CC7 System Operations and Incident Response A.5.24–A.5.28, A.8.15, A.8.16 CC8

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The law also creates a separate, parallel regime for general-purpose AI (GPAI) models, the foundation models behind systems like ChatGPT, Claude, and Gemini. That regime is enforced at the EU level rather than at the national level. Why Was the EU AI Act Created? The official answer is to foster trustworthy AI in Europe. The real answer is broader: the EU watched generative AI go mainstream in late 2022 and concluded that existing law — particularly GDPR — was not enough to address the specific risks AI systems pose. Opacity in decision-making, bias in hiring tools, biometric surveillance, and the manipulation potential of generative models all sat uneasily in the regulatory gap between data protection law and product safety law. The EU’s stated goals are to protect health, safety, and fundamental rights, while preserving innovation and the single market. The political subtext is the Brussels Effect: do for AI what GDPR did for privacy, and let European rules become the global default by virtue of market access. Brazil, Canada, the UK, several US states, and Gulf jurisdictions, including Bahrain, are already drafting AI rules that borrow heavily from the EU framework. For a broader view of how AI governance is likely to evolve through the end of the decade, the trajectory is already becoming clear. Who Does the EU AI Act Apply To? The Act does not apply to AI itself. It applies to people and organisations that build, sell, or use AI systems. Article 3 defines those roles without reference to company size, so a two-person startup is in scope on the same legal basis as a Fortune 500 enterprise. Providers and Developers A provider is anyone who develops an AI system — or has one developed — and places it on the EU market or puts it into service under their own name or trademark. Providers carry the heaviest load of obligations, particularly for high-risk systems: risk management, technical documentation, conformity assessment, post-market monitoring, and incident reporting. A provider is distinct from a downstream developer who simply integrates a third-party AI component. But the line moves: if you take a general-purpose model and put your name on the resulting product, you can become a provider yourself. Deployers and Operators A deployer is anyone using an AI system in a professional capacity. If you are a bank running a credit-scoring model you bought from a vendor, you are a deployer. Deployers have lighter obligations than providers but still carry real ones: ensuring human oversight, monitoring system behaviour, informing affected individuals, and conducting fundamental rights impact assessments where required. The term operator in the Act is an umbrella that covers providers, deployers, importers, distributors, and authorised representatives. Application Outside the EU This is where many non-EU companies get caught. The AI Act applies extraterritorially. A US LLC training a model in Texas, a UK firm running an AI hiring tool, or a Bahrain-based fintech using AI for credit scoring is in scope the moment the output affects someone in the EU. If a US company develops an AI hiring tool and a German employer uses it on German candidates, the US provider is in scope — even with no EU office. The trigger is whether the system’s output is used in the Union, not where the company sits. Pro Tip: Selling AI tools to EU customers outside the EU. If you sell AI tools to EU customers from outside the EU, you must appoint an authorised representative established in a Member State before placing high-risk systems on the market. This is not optional and is one of the most commonly missed obligations for non-EU providers. The Risk-Based Approach: How the EU AI Act Classifies AI Systems The framework sorts AI systems into four tiers. The obligations scale with the tier. Unacceptable Risk: Prohibited AI Practices Article 5 prohibits eight categories of AI practice outright. These prohibitions became enforceable on 2 February 2025, well before the rest of the Act. The banned practices are: Subliminal or manipulative techniques are designed to distort behaviour and cause significant harm. Exploitation of vulnerabilities related to age or disability. Social scoring by public or private actors —