Learn how SAP aligns with the EU AI Act
1
PUBLIC
EU AI Act
Frequently Asked Questions (FAQ)
Version: 1.0
Date: 2025/12/10
PUBLIC
EU AI Act
Frequently Asked Questions (FAQ)
Version: 1.0
Date: 2025/12/10
2
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions related to this material.
Table of contents
1. What is the EU AI Act? .............................................................................................................................................................................. 3
2. How does SAP comply with the EU AI Act? .............................................................................................................................. 3
3. What is SAP’s risk classification methodology for AI features, and what controls follow from
that determination? .................................................................................................................................................................... 4
4. Did SAP check for prohibited practices in their AI usage and development? ................................................. 4
5. Where can customers access information and documentation about SAP’s EU AI Act
compliance? .................................................................................................................................................................................... 4
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions related to this material.
Table of contents
1. What is the EU AI Act? .............................................................................................................................................................................. 3
2. How does SAP comply with the EU AI Act? .............................................................................................................................. 3
3. What is SAP’s risk classification methodology for AI features, and what controls follow from
that determination? .................................................................................................................................................................... 4
4. Did SAP check for prohibited practices in their AI usage and development? ................................................. 4
5. Where can customers access information and documentation about SAP’s EU AI Act
compliance? .................................................................................................................................................................................... 4
3
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions related to this material.
Purpose
This FAQ briefly explains SAP’s high-level approach to aligning its products and services with the
EU AI Act, what customers can expect regarding- transparency and data protection, and how to
request further documentation or support. It is intended to inform customers, partners, and the
wider public—not to replace contractual terms, legal advice, or bespoke compliance
assessments. For specific legal commitments, technical evidence, or deployment level
questions, customers should contact their SAP account team or refer to contractual channels for
additional documentation and redacted evidence where appropriate.
1. What is the EU AI Act?
The EU AI Act is a comprehensive regulatory framework designed to address potential risks
to health, safety, and fundamental rights from the development and use of artificial
intelligence technologies. It adopts a risk-based approach to regulate AI systems and models
and is intentionally phased over several years to ensure regulated entities have adequate
time to meet requirements. The first provisions became applicable in February 2025, with
additional phases to follow.
2. How does SAP comply with the EU AI Act?
As part of SAP’s broader global regulatory compliance strategy, SAP commits to complying
with all laws and regulations applicable to its business operations, including applicable obligations
under the EU AI Act. In addition to these contractual commitments, SAP has demonstrated its
approach to implementing EU AI Act requirements through the following compliance initiatives:
• Signing the EU AI Pact, a set of voluntary pledges developed by the AI Office to support
regulatory readiness ahead of some of the upcoming compliance deadlines for the EU AI Act.
• Conducting AI systems classification aligned with EU AI Act categories (prohibited, high-risk,
limited risk, etc.).
• Implementing an AI governance framework and management system based on
internationally recognized standards (for example, ISO 42001).
• Applying industry standards security assessments, administrative policies, integrity testing,
and employee awareness training to consistently maintain responsible deployment of AI
capabilities including AI systems, AI technology and AI features in SAP software.
• Establishing organizational structures – including a dedicated team of committees and
subject-matter experts - to safeguard ongoing compliance with EU AI Act requirements.
• Initiated project workstreams that follow the phased applicability timelines of the EU AI Act’s
individual chapters and sections.
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions related to this material.
Purpose
This FAQ briefly explains SAP’s high-level approach to aligning its products and services with the
EU AI Act, what customers can expect regarding- transparency and data protection, and how to
request further documentation or support. It is intended to inform customers, partners, and the
wider public—not to replace contractual terms, legal advice, or bespoke compliance
assessments. For specific legal commitments, technical evidence, or deployment level
questions, customers should contact their SAP account team or refer to contractual channels for
additional documentation and redacted evidence where appropriate.
1. What is the EU AI Act?
The EU AI Act is a comprehensive regulatory framework designed to address potential risks
to health, safety, and fundamental rights from the development and use of artificial
intelligence technologies. It adopts a risk-based approach to regulate AI systems and models
and is intentionally phased over several years to ensure regulated entities have adequate
time to meet requirements. The first provisions became applicable in February 2025, with
additional phases to follow.
2. How does SAP comply with the EU AI Act?
As part of SAP’s broader global regulatory compliance strategy, SAP commits to complying
with all laws and regulations applicable to its business operations, including applicable obligations
under the EU AI Act. In addition to these contractual commitments, SAP has demonstrated its
approach to implementing EU AI Act requirements through the following compliance initiatives:
• Signing the EU AI Pact, a set of voluntary pledges developed by the AI Office to support
regulatory readiness ahead of some of the upcoming compliance deadlines for the EU AI Act.
• Conducting AI systems classification aligned with EU AI Act categories (prohibited, high-risk,
limited risk, etc.).
• Implementing an AI governance framework and management system based on
internationally recognized standards (for example, ISO 42001).
• Applying industry standards security assessments, administrative policies, integrity testing,
and employee awareness training to consistently maintain responsible deployment of AI
capabilities including AI systems, AI technology and AI features in SAP software.
• Establishing organizational structures – including a dedicated team of committees and
subject-matter experts - to safeguard ongoing compliance with EU AI Act requirements.
• Initiated project workstreams that follow the phased applicability timelines of the EU AI Act’s
individual chapters and sections.
4
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions related to this material.
3. What is SAP’s risk classification methodology for AI features, and what controls
follow from that determination?
SAP has initiated a formal classification of its AI systems in line with the EU AI Act categories
(prohibited, high‑risk, limited‑risk, and minimal risk). Each AI feature is being assessed by intended
purpose and deployment context, potential impact on fundamental rights, safety and compliance,
and whether the use case maps to high-risk categories.
High-risk classification triggers full lifecycle controls, including but not limited to AI risk management,
data governance for training, validation and test data, technical documentation, human oversight,
accuracy and robustness testing, and post-market monitoring.
Non-high-risk features receive proportionate controls, clear user transparency, security safeguards,
and alignment with SAP’s Global AI Ethics Policy. Classifications are documented and reviewed as AI
features evolve.
Once the review is complete, we will register the relevant AI systems in the EU’s official AI database,
as required by the EU AI Act. We will also share the required information about any high-risk
designations, including the rationale behind them and the mitigation measures we will apply.
4. Did SAP check for prohibited practices in their AI usage and development?
Yes, SAP assesses its AI systems and features to ensure compliance with the EU AI Act, including
verification against the prohibited practices set out in Article 5. If a prohibited practice under Article
5 is identified during the assessment of a newly developed AI feature, its development is
immediately stopped. SAP has implemented controls to help ensure that no AI features involving
prohibited AI practices are used, developed or distributed.
5. Where can customers access information and documentation about SAP’s EU AI Act
compliance?
SAP will provide customers with the necessary information about AI systems to help them
understand their responsibilities under the EU AI Act. Additional materials will be made available as
regulatory guidance evolves. Customers can request documentation via their SAP account team or
the Trust Center.
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions related to this material.
3. What is SAP’s risk classification methodology for AI features, and what controls
follow from that determination?
SAP has initiated a formal classification of its AI systems in line with the EU AI Act categories
(prohibited, high‑risk, limited‑risk, and minimal risk). Each AI feature is being assessed by intended
purpose and deployment context, potential impact on fundamental rights, safety and compliance,
and whether the use case maps to high-risk categories.
High-risk classification triggers full lifecycle controls, including but not limited to AI risk management,
data governance for training, validation and test data, technical documentation, human oversight,
accuracy and robustness testing, and post-market monitoring.
Non-high-risk features receive proportionate controls, clear user transparency, security safeguards,
and alignment with SAP’s Global AI Ethics Policy. Classifications are documented and reviewed as AI
features evolve.
Once the review is complete, we will register the relevant AI systems in the EU’s official AI database,
as required by the EU AI Act. We will also share the required information about any high-risk
designations, including the rationale behind them and the mitigation measures we will apply.
4. Did SAP check for prohibited practices in their AI usage and development?
Yes, SAP assesses its AI systems and features to ensure compliance with the EU AI Act, including
verification against the prohibited practices set out in Article 5. If a prohibited practice under Article
5 is identified during the assessment of a newly developed AI feature, its development is
immediately stopped. SAP has implemented controls to help ensure that no AI features involving
prohibited AI practices are used, developed or distributed.
5. Where can customers access information and documentation about SAP’s EU AI Act
compliance?
SAP will provide customers with the necessary information about AI systems to help them
understand their responsibilities under the EU AI Act. Additional materials will be made available as
regulatory guidance evolves. Customers can request documentation via their SAP account team or
the Trust Center.