Implementing the AI Act in higher education and research: compliance tools and worker participation

Abstract

This chapter operationalises the AI Act in the HER context, translating complex legal provisions into sector-specific guidance. It offers a sector-specific, rights-focused regulatory analysis of the Act, identifying where the horizontal provisions fall short of sector-specific needs, noting that these are expected to be supplemented by harmonised standards developed by the European Committee for Standardization (CEN) and the European Committee for Electrotechnical Standardization (CENELEC) for operational compliance and by European Commission guidelines. In line with the New Legislative Framework logic, the chapter treats these standards and guidelines, together with emerging AI management system standards such as ISO/IEC 42001, as part of the governance toolkit that higher education institutions can use to become involved in the implementation of the legal obligations. Beyond the legal analysis, the chapter translates the legal obligations into a practical tool to support compliance, identifying intervention points which are especially relevant in the context of collective bargaining (see Section 4). It also proposes sector-specific fundamental rights impact assessments (FRIA) and reporting mechanisms aimed at supporting compliance, worker participation and accountability in practice. All these elements could help HER institutions move from a legal reading of the Act to an approach oriented towards implementation that connects fundamental rights, labour and data protection law with the specific compliance architectures used in product safety and AI governance.