EU AI Act enforcement powers begin August 2 2026 with investigations orders and fines up to €35 million or 7 percent worldwide turnover. ISO/IEC 42001 published December 2023 is the world's first AI management system standard held by Microsoft PwC Canada Cornerstone and hundreds of others. ISO 42001 as of 2026 is not a harmonised standard under the EU AI Act and confers no presumption of conformity. Harmonised standard prEN 18286 developed by CEN-CENELEC JTC 21 entered public enquiry October 30 2025 - not listed in Official Journal. ISO 42001 is a management system standard specifying organisational processes not product-level technical controls. EU AI Act Articles 12 14 and 17 require product-level logging human oversight and quality management technical evidence. ISO 42001 does not specify what those product-level technical controls must contain. Constitutional command layer - cryptographic audit trails tamper-resistant override logs pre-execution gates - is the bridge that prEN 18286 will eventually specify.
Read paper: https://doi.org/10.5281/zenodo.21216857
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