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AI Governance Guide
Expert verified by Kevin A, CISSP

AI Compliance for Healthcare

Healthcare AI systems are classified as high-risk under the EU AI Act. From diagnostic imaging to clinical decision support, your AI must meet rigorous safety, transparency, and governance requirements.

EU AI Act Classification: HIGH RISK

EU AI Act Risk Classification for Healthcare

Medical Devices & Diagnostics

AI systems intended for medical diagnosis, prognosis, or treatment recommendations.

Examples in Healthcare:

  • AI-powered radiology analysis
  • Pathology slide interpretation
  • Symptom checkers recommending treatment
  • Predictive patient deterioration alerts

Clinical Decision Support

Systems that influence clinical decisions about patient care.

Examples in Healthcare:

  • Drug interaction checkers
  • Treatment pathway recommendations
  • Risk stratification models
  • Sepsis prediction algorithms

Patient-Facing Chatbots

AI systems interacting with patients requiring transparency disclosures.

Examples in Healthcare:

  • Appointment scheduling bots
  • Symptom triage chatbots
  • Mental health support assistants
  • Medication reminder systems

Administrative AI

Back-office AI with minimal patient impact.

Examples in Healthcare:

  • Medical coding automation
  • Claims processing optimization
  • Supply chain management
  • Staff scheduling algorithms

August 2026 Deadline

Healthcare companies deploying AI in the EU must achieve compliance by August 2026. Start your readiness assessment now to avoid rushing implementation or facing penalties up to 7% of global revenue.

Key Requirements for Healthcare AI

01

Clinical Validation & Testing

AI systems must be validated against clinical outcomes with representative patient populations. Document sensitivity, specificity, and performance across demographic groups.

EU AI Act Art. 9ISO 42001 Clause 8.3FDA AI/ML Guidance
02

Bias Testing Across Demographics

Test and document AI performance across age, sex, ethnicity, and health conditions. Implement ongoing monitoring for performance drift.

EU AI Act Art. 10ISO 42001 Clause 6.1NIST AI RMF
03

Human-in-the-Loop Requirements

Clinical AI must support, not replace, clinician judgment. Design for appropriate human oversight in diagnostic and treatment decisions.

EU AI Act Art. 14ISO 42001 Clause 8.1MDR 2017/745
04

Explainability for Clinicians

Provide clinicians with interpretable outputs explaining AI reasoning. Document model logic and limitations in clinical contexts.

EU AI Act Art. 13ISO 42001 Clause 8.4HIPAA
05

Patient Data Governance

Implement robust data governance for PHI used in AI training and inference. Ensure HIPAA compliance and EU data protection requirements.

EU AI Act Art. 10ISO 42001 Clause 7.2HIPAAGDPR
06

Continuous Performance Monitoring

Implement real-time monitoring for model drift, accuracy degradation, and adverse events. Establish incident response protocols.

EU AI Act Art. 61ISO 42001 Clause 9.1FDA Post-Market

Implementation Roadmap

Follow this Healthcare-specific roadmap to achieve AI compliance. Most organizations complete these steps in 6-12 months.

1

Inventory all AI systems touching patient care or clinical workflows

2

Classify each system under EU AI Act risk tiers and MDR/IVDR where applicable

3

Conduct clinical validation studies with diverse patient populations

4

Implement bias testing and demographic performance analysis

5

Design human oversight workflows for high-risk clinical AI

6

Establish data governance for PHI in AI pipelines

7

Document model explainability and clinician-facing disclosures

8

Create incident response and adverse event reporting processes

Start Your AI Governance Journey

Get a personalized readiness score and action plan for your Healthcare AI systems. Our calculator maps your current state to ISO 42001 and EU AI Act requirements.

Get Free AI Readiness Score

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Healthcare AI Compliance FAQs

Does the EU AI Act apply if we only serve US patients?

If your AI system is used to make decisions about EU citizens or is marketed in the EU, the AI Act applies. Many US healthcare companies with international operations or EU customers will need to comply.

How does the EU AI Act interact with FDA AI/ML regulations?

They are complementary but distinct. FDA focuses on safety and effectiveness for US market authorization. The EU AI Act adds transparency, bias testing, and governance requirements. Organizations selling in both markets need to satisfy both frameworks.

Is ISO 42001 required for healthcare AI?

Not legally required, but increasingly expected by health systems and payers. ISO 42001 certification demonstrates systematic AI governance and can streamline EU AI Act compliance. Many procurement processes now ask about AI management systems.

What about AI used only for research, not clinical care?

Research-only AI may fall outside high-risk classifications if not used for clinical decisions. However, if research AI informs patient care or transitions to clinical use, it becomes subject to full requirements.

KA

Kevin A

CISSPCISMCCSPAWS Security Specialist

Principal Security & GRC Engineer

Kevin is a security engineer turned GRC specialist. He focuses on mapping cloud-native infrastructure (AWS/Azure/GCP) to modern compliance frameworks, ensuring that security controls are both robust and auditor-ready without slowing down development cycles.

About RiscLens

Our mission is to provide transparency and clarity to early-stage technology companies navigating the complexities of SOC 2 (System and Organization Controls 2) compliance.

Who we serve

Built specifically for early-stage and growing technology companies—SaaS, fintech, and healthcare tech—preparing for their first SOC 2 audit or responding to enterprise customer requirements.

What we provide

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Technical Definition

SOC 2 (System and Organization Controls 2) is a voluntary compliance standard for service organizations, developed by the AICPA, which specifies how organizations should manage customer data based on the Trust Services Criteria: security, availability, processing integrity, confidentiality, and privacy.