You will receive the technical file, the conformity strategy and your contracts.
§ 1
Approach
We will settle transparency first: the notices and the marking of the content your system generates.
We will draft with your team the technical documentation required by Annex IV, with time to do it properly before 2027.
We will prepare the conformity assessment, the EU declaration and registration in the European database where your system requires it.
§ 2
Engagement
El importe exacto se cierra en la hoja de encargo antes de pagar, con los gastos previsibles incluidos. Si el encargo se alarga, no pagas más.
§ 3
Process
A unilateral confidentiality agreement signed by PASSAS before the video consultation, available at no additional cost on request. It binds the firm alone — no signature is required from the client — and adds an explicit contractual layer on top of the professional secrecy obligations inherent to the practice of law.
A 60-minute working session by video call in which we analyse your situation, your specific needs and our ability to help you. We assess whether we can take on the matter and give you the fixed price in advance. You can book it directly through the Google Calendar link on our website and pay €90 by Stripe.
Legal analysis of the artificial intelligence systems the company operates or deploys under Regulation (EU) 2024/1689. Determines the company's regulatory role (provider, deployer or both), classifies each system according to the AI Act risk tiers and establishes the map of applicable obligations. The documentary basis on which any compliance process is built.
Technical documentation of the AI system in accordance with Annex IV of the AI Act: general description of the system, development process, training data, performance metrics, risk management and human oversight measures. It is the core of the file the provider must keep available to the authorities, and the basis on which the conformity assessment is built.
Strategy and execution of the conformity assessment applicable to the system, drafting of the EU declaration of conformity and registration in the European database where required. Closes the formal cycle that allows the provider to place the system on the Union market with a documented regulatory position, defensible before any authority.
The documentation required for GDPR compliance and, more broadly, for any rules on data protection and on the processing and transfer of data, including international transfers, both in dealings with users and with the providers that process data on your behalf, with the legal mechanisms needed to operate without regulatory exposure.
Contractual documentation to formalise relationships with clients and suppliers, with the terms, liabilities and scope clearly defined from the first engagement. Includes the services agreement adapted to the company's operations, with limitation of liability clauses and payment terms, ready to sign.
Public statement on the use of artificial intelligence in the company's products and processes: which systems are used, for what purpose and with what safeguards for the users affected. A deliverable that clients, regulators and investors will demand with increasing frequency, and that few firms are yet in a position to provide.
§ 4
Team
I see legal practice as a discipline of precision. I work where the law meets technology and cross-border operations, and I read code and contracts with the same attention. Before accepting an engagement I tell you whether it is worth pursuing and what it costs, at a fixed price.
I work where economic law meets technology: litigation, contracts and artificial intelligence systems. I am drawn to the ground where the rules are still being written, and I have brought that same rigour to litigation since my first year in practice.
§ 5
Questions
Since 2 August 2026, telling people that they are interacting with an AI system and marking, in a machine-readable way, the audio, images, video or text it generates (article 50). Systems placed on the market before that date have until 2 December 2026 for marking, the same day the two prohibitions added to article 5 by Regulation (EU) 2026/1744 take effect. AI literacy under article 4 has applied since February 2025, and if you train or place on the market a general-purpose model, its obligations have applied since 2 August 2025.
Quite possibly. You are a provider if you develop a system, or have it developed, and place it on the market under your own name. For high-risk systems, article 25 also moves a distributor, importer or deployer into that role by putting their name on a system already on the market, making a substantial modification or changing its intended purpose. Companies that build a product on top of a third party model routinely occupy that position without having identified it.
Regulation (EU) 2026/1744, in force since 27 July 2026, moved the high-risk regime to 2 December 2027 for Annex III systems and 2 August 2028 for Annex I systems. The technical documentation, quality management system, conformity assessment, CE marking and registration in the EU database apply from those dates, and preparing them takes months.
The Regulation applies directly, but fines for breaching it require a Spanish law defining the infringements and giving the Spanish AI supervisory authority power to sanction. The bill lapsed on 6 October 2026 when Parliament was dissolved, and the next legislature will have to start again. In the meantime the Spanish data protection authority acts under the GDPR wherever the system processes personal data, and the Commission has been able to fine providers of general-purpose models since 2 August 2026.
From €12,000 + VAT, delivered within six weeks, at a fixed price agreed in the engagement letter before we begin. The exact price depends on the number of systems and on how mature your existing technical documentation is.
It can help you assemble parts of the file, and many do it competently. What it cannot do is decide, with professional liability attached, whether you are a provider and whether the system is high risk. Those determinations govern everything else in the file, they are questions of legal interpretation, and a consultancy is in no position to sign them. If you want that question answered before committing, a 60 minute Virtual Consultation costs €90 (VAT included) and is deductible from the first invoice.
Sixty minutes on Google Meet with a qualified lawyer. It costs €90 including VAT and will be deducted from the first invoice if an engagement follows.
