How to choose an EU AI Act consultant in Taiwan: eight criteria

When choosing an EU AI Act consultant, first check whether they can determine your role in each AI system (provider, deployer, importer or distributor) and its risk level; then check whether they can explain the application dates as amended by the Digital Omnibus, the high-risk obligations and the conformity assessment route, and what ISO/IEC 42001 can and cannot do.

Updated 2026-10-28

Direct answer: the first question to ask an EU AI Act consultant is "what risk level does each of my AI systems fall into, and am I its provider or its deployer?" The EU AI Act (Regulation (EU) 2024/1689) sets obligations by risk: the AI practices prohibited by Article 5(1), points (a) to (h), apply from 2 February 2025 (the Digital Omnibus adds two more points, applying from 2 December 2026); providers of high-risk AI systems must meet requirements on risk management, data governance, technical documentation, record-keeping, human oversight and accuracy, and complete a conformity assessment; and Article 50 sets transparency obligations for AI that interacts with people, for synthetic content and for deep fakes, applying from 2 August 2026. A Taiwanese company with no establishment in the EU is still in scope if it places an AI system on the EU market or if the output of its AI system is used in the EU (Article 2(1)). Next, check that the consultant knows the latest dates: the Digital Omnibus on AI (Regulation (EU) 2026/1744, in force since 27 July 2026) moved the high-risk obligations to 2 December 2027 for Annex III systems and 2 August 2028 for Annex I products; and that they can explain that ISO/IEC 42001 is not a harmonised standard under the EU AI Act, so certification does not mean legal compliance.

Four roles

RoleWhoMain obligations
ProviderDevelops an AI system or general-purpose AI model and places it on the market or puts it into service under its own nameHigh-risk: Articles 9 to 17, conformity assessment, EU declaration of conformity, CE marking, registration
DeployerUses an AI system in the course of its businessHigh-risk: use according to the instructions, assign competent people to human oversight, keep logs for at least 6 months; certain deployers must carry out a fundamental rights impact assessment
Importer, distributorBrings a non-EU provider's AI system into, or makes it available on, the EU marketCheck that the provider has met its obligations and that marking and documentation are complete
Authorised representativeRepresentative in the EU appointed by written mandate by a non-EU provider of high-risk AICarries out the tasks in the EU mandated by the provider (Article 22)

Eight criteria

CriterionQuestion you can ask any consultant
Determining rolesIn each AI system, am I the provider, deployer, importer or distributor? On what basis?
Risk classificationDoes my system fall under the Article 5 prohibitions, high-risk under Annex I or Annex III, Article 50 transparency, or the Article 6(3) exemption? An Annex III system that profiles natural persons is always high-risk; how is the decision recorded?
Application datesWhich date applies to my system? Annex III systems: 2 December 2027; Annex I Section A products: 2 August 2028; Annex I Section B products such as vehicles, civil aviation and machinery are handled through sector legislation under the amended Article 2(2). Can you tell them apart?
High-risk obligationsWhat evidence is needed for risk management, data governance, technical documentation, record-keeping, human oversight, and accuracy and robustness?
Conformity assessment routeDoes my system go through internal control (Annex VI) or need a notified body (Annex VII)? Do I need an EU authorised representative and registration in the EU database?
Fundamental rights impact assessmentArticle 27 requires it only of bodies governed by public law, private entities providing public services, and deployers of credit-scoring or life and health insurance pricing systems. Am I one of them? Can it cross-refer to a data protection impact assessment under GDPR Article 35?
Relationship with ISO/IEC 42001Which organisational requirements can ISO/IEC 42001 carry, and which legal obligations can it not replace? How does a provider's quality management system map to the harmonised standard already published?
Who leads, and is work subcontractedWho actually runs the engagement, with what qualifications? Will any of it be subcontracted?

When you may not need a consultant

If your AI systems are not placed on the EU market and their output is not used in the EU, the EU AI Act usually does not apply. If you only use general-purpose generative AI tools for purposes that are not high-risk, the main work is AI literacy measures under Article 4 (amended in July 2026 to "take measures to support the development of AI literacy", with no specific level guaranteed) and internal rules on Article 50 transparency; when you need a judgment on legal liability, consult a lawyer.

How Winners Consulting addresses these criteria

What follows is Winners Consulting's own description. Test us with the questions above, just as you test other consultants.

Related questions

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Compliance needs all three; a consultant's value is integration

CRA, TISAX, ISO 27701 and the AI Act are not single technical problems. They are only complete when process, security technology and legal compliance all hold at the same time. Fix only one and the gaps in the other two surface during audits, incident reporting or customer due diligence, and the work has to be redone.

DimensionThe question it answersTypical gap when only this part is done
Process (management system)Who is responsible, what is done, when, where the evidence is, how it improvesTools are in place but nobody runs them on schedule, so there are no records at audit time
Security technologyHow controls are designed and how their effectiveness is verifiedDocuments are complete but the systems do not actually do what they describe
Legal complianceWhich regulation applies, which role you hold, the deadlines and penaltiesControls are built against the wrong regulation or role, so obligations are not covered

Winners' consulting team covers all three dimensions and plans regulatory scoping, process design and technical controls together, so a single body of evidence serves multiple regulations and customer requirements.

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