Notes on AI governance and technology oversight from the boardroom.
I publish about one insight per month on AI governance and board-level technology oversight.
- 8 min read
Anatomy of an ATS: why your recruitment system already binds you (even though the AI Act has been postponed)
Your company almost certainly operates an ATS that filters and scores candidates. The postponement of the AI Act's high-risk obligations to 2027 does not exempt you: Spanish employment and data-protection law already binds you today. Anatomy of a high-risk system that almost no one has classified.
- Topics:
- EU AI Act
- Annex III
- Employment
- HR
- Compliance
- 7 min read
The EU AI Act's moving deadline: how it evolved, the postponement to 2027, and what doesn't change for your board
The EU AI Act's timeline has been a moving target from the start — and in 2026 it moved again: the 'Digital Omnibus' postpones high-risk obligations from 2026 to late 2027. The story of that evolution, and the governance lesson: the deadline moves; the duty does not.
- Topics:
- EU AI Act
- Digital Omnibus
- Corporate governance
- Regulation
- 8 min read
Annex III of the EU AI Act: the practical list of high-risk systems you are probably already operating
Annex III of Regulation (EU) 2024/1689 defines eight categories of AI systems considered high risk. This is the practical list with real examples to audit your organisation before August 2026.
- Topics:
- EU AI Act
- Annex III
- High risk
- Compliance
- 12 min read
The thesis: why technology oversight needs its own board committee in 2026
An argued essay: the regulatory convergence of 2025-2026 has overwhelmed the traditional audit committee. The Spanish board already has the legal framework to constitute a specialised committee on technology, data and AI. I defend why to do it now, and why doing nothing is a worse decision than any alternative.
- Topics:
- Corporate governance
- Thesis
- Recommendation 23
- EU AI Act
- DORA
- NIS2
- 7 min read
EU AI Act: what a board must have settled before August 2026
The EU AI Regulation reaches full application on 2 August 2026. These are the decisions the board cannot delegate — and the realistic timeline to make them.
- Topics:
- EU AI Act
- AI Governance
- Compliance
- 6 min read
The independent director missing on many Spanish boards: the technology one
Recommendation 23 of the Spanish Good Governance Code allows additional specialised committees. More and more boards are realising technology no longer fits inside the audit committee.
- Topics:
- Corporate governance
- Board of directors
- Technology oversight
- 5 min read
Family business and AI: three questions the chair should be able to answer in an hour
Spanish family businesses are tackling AI without the safety net of the compliance apparatus that listed companies have. These are the three questions I recommend the chair clarifies before approving the next AI investment.
- Topics:
- Family business
- AI governance
- Advisory board