| BEFORE YOU START: WRITE TO ME This newsletter grows with you.SIGNAL AI should grow through your questions. Reply to this email to comment on an article, discuss my analysis or suggest a topic related to your work. I will gladly respond. A reasoned disagreement, a practical difficulty or a use that works: your feedback can inform future editions. Please say whether you agree to be quoted; your message will not be published without your consent. Comment or suggest a topic ↗ | | KEEPING AI HUMAN | BY JÉRÔME DENIS |
| 1 NOVEMBER 2026 · SUNDAY EDITION AI Act: the day an employee demands answers.47 articles and practical ideas · 10 sections · A feature, a fictional story and a tutorial. Selected from the week of 26 October, with dated background references. Choose a section ↓ | | A minute to reflect.The feature uses a fictional dismissal to examine data, oversight and remedies. A validation click does not tell us everything about the manager’s work. High-risk HR in December 2027, other rules already applicable: begin by classifying the system and its purpose, then check obligations and transitional provisions. Five practical ideas, a named owner and a verifiable result. The tutorial helps assemble the evidence before extending use. | Where does your company stand?Start your compliance work with an initial risk assessment. My AI Act checker helps classify a use and identify questions to examine. The result is indicative: it is neither an audit nor a certification. The questionnaire is in French. Try the AI Act checker ↗Then prepare your file in 45 minutes ↓ |  | A word from JérômeJDENIS Consulting · Toulouse |
Hello everyone, A company can use AI for months without any apparent conflict. Then someone challenges a decision. The discussion changes: the company must explain which data it used, what role the system played and what the manager actually checked. This week, I have chosen to begin with a fictional dismissal. It lets us examine an ordinary sequence: a support tool becomes a metric, the metric becomes a ranking, and that ranking then affects someone’s career. The story predicts neither a finding against the employer nor an amount of compensation. It raises questions an organisation should be able to investigate before reaching a courtroom. One common shorthand also needs correcting: the AI Act does not have a single date on which all its provisions become applicable. The timetable changed in 2026, while employment law and the GDPR continue to apply. Here I distinguish legal obligations, recommendations and my own proposals. The other selections retain our focus on occupations, practical uses and the transformation of work. You will also find five trials for microbusinesses and SMEs, longer commentaries and a tutorial for preparing an initial governance file. My AI Act checker offers a starting point: it helps identify a risk category, without certifying compliance. Connect with me on LinkedIn ↗ | Find your signal.The story: Marc challenges his dismissalAI Act: when an HR decision becomes a disputeOccupations and the transformation of workAI in everyday workMicrobusinesses and SMEs: five uses to tryTechnology: what changes for teamsCosts and investment choicesIndustry and work in the fieldEthics: the people behind the metricsPolicy and governance: preparing for the deadlinesCreative work and content productionThe tutorial: your file in 45 minutesYour questions and commentsThe connecting thread | A STORY FOR DISCUSSION · FICTIONAL CASE Marc had never seen his score.FICTIONAL CASE · France, September 2028. The people, company and events are invented. Assumption: a new high-risk HR system entered service in June 2028, after the applicable December 2027 deadline. The analysis uses the law as it stands on 1 November 2026, without anticipating future changes. Marc has worked for nine years in the customer service department of a company with eighty employees. His performance has always been considered satisfactory. In spring, management activates a new software module: it combines response times, closed cases and internal comments to produce a “contribution” metric. Employees know that tracking software exists. Nobody explains that their data now feeds an AI assessment that could influence an employment decision. The project seems limited in scope. The HR lead relies on the supplier’s assurances; the line manager believes the tool helps prepare performance reviews. IT considers access secure. Everyone checks part of the arrangement, but nobody takes responsibility for how it is used as a whole. The documentation does not explain how an employee can challenge a score. In September, Marc is dismissed for inadequate professional performance. At the pre-dismissal meeting, his manager had described his contribution as “consistently below that of the team”. Marc had explained that he handled the most difficult complaints and supported two new colleagues. These tasks take longer and do not always result in a closed case. His explanation had not changed the assessment. After receiving notice, Marc requests the data used to assess him. He discovers an automated summary that repeats his manager’s reasons almost word for word. He asks when a manager checked the underlying cases. The company finds a validation click, but no comments showing that his objections were examined. This alone does not prove the dismissal was unlawful. It does, however, weaken the claim that his circumstances received an individual review. With his legal adviser, Marc brings a claim before the French employment tribunal, the conseil de prud’hommes, to challenge the dismissal. He disputes, among other things, the assessment methods, the lack of information and the relevance of the evidence relied on. A separate complaint to the CNIL, France’s data protection authority, may concern the processing of his data. Alleged AI Act breaches fall under the oversight and remedy procedures provided by that regulation: these proceedings are distinct. At the hearing, the question is not simply “did you use AI?” The tool’s purpose, the information given to Marc, the reliability of the data and the actual role of human judgement must be examined. The employer may produce evidence of professional performance independent of the score; Marc may challenge its significance. Any allegation of discrimination calls for a specific analysis. Failure to inform does not automatically make the dismissal void, lead to reinstatement or trigger the maximum fine. The story stops before judgement. Its lesson concerns organisation: when a dispute arises, the company must be able to explain a decision it previously treated as a simple software output. Providing information, documenting the process and allowing genuine reconsideration would have changed its quality, without guaranteeing the absence of disagreement. References for analysing this case: L1222-3 (since 2008) · L1222-4 (since 2008) · GDPR, Art. 22 (applicable since 2018) · Annex III (consolidated 27 July 2026) · AI Act: Article 26 (consolidated 27 July 2026) · French Ministry of Labour (accessed 1 Nov 2026) | | 01 | AI Act: when an HR decision becomes a dispute5 ITEMS · SOURCES AND DATES INCLUDED |
Our main feature. Obligations, reasons for bypassing them and possible consequences. Legal position checked on 1 November 2026. 1. The timetable no longer has a single dateThe AI Act entered into force in 2024. Following the 2026 omnibus, the rules for high-risk systems covered by Annex III, including certain HR uses, will apply on 2 December 2027; those for high-risk systems embedded in regulated products will apply on 2 August 2028. Some rules already apply. Earlier systems also have transitional provisions: their dates and modifications matter. Sourced analysis · European Commission (19 Oct 2026) · AI Act: Article 111 (consolidated 27 July 2026) 2. An HR tool cannot be classified by its nameAnnex III covers, among other things, systems that influence recruitment, assessment, task allocation or termination of employment. A writing assistant is therefore not equivalent to an employee ranking used to dismiss someone. The purpose and actual influence of the output, as well as the stated exceptions, must be examined before drawing a conclusion. Sourced analysis · Annex III (consolidated 27 July 2026) 3. Why a company can miss the issueFive mechanisms deserve examination: an AI feature activated in existing software; a pilot that becomes permanent; excessive trust in the supplier; a regulatory delay mistaken for an exemption; and cost pressure that reduces review. These are hypotheses for an organisational diagnosis, not findings from a prevalence survey. Proposed analytical framework · AI Act: Article 26 (consolidated 27 July 2026) 4. A recommendation is not an obligationThe regulation’s obligations, the supplier’s instructions and non-binding guidance must be distinguished. Within the scope of Article 26, an employer acting as deployer will, among other things, need to arrange competent oversight and inform affected workers and their representatives before use. A good-practice sheet helps organise the work; it does not replace applicable obligations. Sourced analysis · AI Act: Article 26 (consolidated 27 July 2026) 5. Maximum penalties, not an automatic tariffArticle 99 provides, among other penalties, for up to €35 million or 7% of worldwide turnover for certain prohibited practices, and €15 million or 3% for specified breaches, including those of Article 26. For SMEs, the lower ceiling applies. Severity, circumstances and proportionality matter. These administrative penalties are separate from any remedies an employee may obtain. Sourced analysis · AI Act: Article 99 (consolidated 27 July 2026) My perspective I do not believe fear of a fine is enough to produce serious governance. It can even encourage superficial compliance: a charter signed, training completed, then decisions made exactly as before. What seems decisive to me is the ability to reconstruct the reasoning that led to a person being treated in a particular way. This requirement also protects the employer. A manager should be able to explain what they accepted from an automated analysis, what they rejected and why. That requires time, skills and sometimes the ability to challenge a productivity target. Without those conditions, “human validation” risks becoming one more signature. Regulation alone will not resolve this organisational contradiction. It will, however, make it harder to leave it invisible until the first dispute. I would focus the company’s preparation here, on the actual work of its managers. |
BACK TO CONTENTS ↑ | | 02 | Occupations and the transformation of work5 ITEMS · SOURCES AND DATES INCLUDED |
Training, assessment and decisions: AI redistributes tasks, but also opportunities to learn and to challenge an outcome. Skills: judgement still needs to be taughtThe joint report published by the ILO describes a reshaping of cognitive, social and digital skills. It emphasises the ability to understand and use AI safely. It is not a detailed forecast of job losses. For training managers, its value lies in connecting learning about a tool to the work situations in which it will actually be used. Background report · ILO and partners (13 Aug 2026) Skills shortages also hold back small businessesThe OECD synthesis identifies skills as a barrier to adoption, particularly in SMEs. Training focused solely on operating an interface leaves out defining the problem, selecting data and checking results. One approach is to follow a complete case handled by the team and identify the points at which people hesitate. Background report · OECD (2026, background report) Public-sector HR offers a working frameworkThe ministerial framework of 23 April 2026 brings together confidentiality, training and complementarity with human expertise. It applies to the ministries concerned, rather than introducing a rule for every company. It nevertheless provides a useful example: describe the conditions of use before multiplying assistants across HR processes. Institutional reference · French Ministry of Education (23 April 2026) Candidates retain rights over their dataThe CNIL guide sets out requirements concerning the information collected, its retention and candidates’ rights. A tool that automatically enriches a profile does not make every piece of data relevant. The practical question remains specific: what information is needed to assess suitability for this job? Legal reference · CNIL guide (Background: Jan 2023) Run a session in which the junior challenges the AISuggested trial: ask a beginner and an experienced professional to examine an AI response containing a realistic error, separately. Compare their reasoning, then write a checking rule. Measure the errors identified and the explanations provided, without turning this learning exercise into an individual ranking. The intended result is a shared method, not a score for prompting fluency. Suggested use · ILO and partners (13 Aug 2026) My perspective I would be cautious about reducing skills management to how often someone uses an assistant. Usage frequency tells us about a practice, not directly about the quality of work. An employee may rarely use the tool because they handle the most difficult situations; another may produce more while passing the checking work to colleagues. The studies presented here invite us to observe work in greater detail: which errors are detected, which lines of reasoning become explicit, which learning opportunities disappear? I would also preserve space for beginners and experts to compare methods without turning every trial into a performance measure. The aim is not to preserve every task unchanged. It is to understand how people develop professional competence when some steps are delegated. A company that measures only speed may discover too late that it has weakened the skills needed for oversight. |
BACK TO CONTENTS ↑ | | 03 | AI in everyday work5 ITEMS · SOURCES AND DATES INCLUDED |
Deployments and methods that help explain the move from access to a tool to usefulness for a team. Japan reports gains, alongside explicit reservationsThe Digital Agency collected 6,439 responses about Gennai. It estimates time saved at 1.83 hours per week per user, based on responses given in ranges. Some staff report reliability or workload problems. This is a usage survey, not an experiment demonstrating identical gains across departments. Reported user experience · Digital Agency, Japan (30 Oct 2026) Synthetic data to put Copilot to the testMicrosoft Research presents synthetic enterprise environments, with documents, meetings and organisational relationships, to evaluate Copilot without using customer data. The approach brings testing closer to business processes. It does not, by itself, establish how the system behaves in a real organisation; local situations still need checking. Method published by the vendor · Microsoft Research (30 Oct 2026) Transcribing meetings without erasing uncertaintyNVIDIA has released a model combining transcription, speaker attribution and translation, with capabilities that differ by language. For a team, useful checks concern names, amounts and who made each commitment. Fluent output may be wrong on precisely the detail that commits a person to something. Technical announcement; performance claims attributed · NVIDIA (28 Oct 2026) Check an agent’s quality in the result it leaves behindAgentProofBench studies reusable verification rules for web agents. The practical principle is to check the resulting state, rather than just the announcement of success. Suggested example: a CRM update should leave the right field in the right record, with a verifiable value. This preprint does not certify agents. Preprint and practical suggestion · AgentProofBench (25 Oct 2026, preprint) Meeting minutes should be able to say “unconfirmed”Suggested trial: the assistant prepares a list of decisions, with a supporting excerpt for each. The meeting lead confirms owners and deadlines; ambiguous points remain visible. Compare ten sets of minutes with participants’ corrections. Success means fewer misunderstandings, taking checking time into account. Suggested use · Microsoft Research (30 Oct 2026) My perspective The Japanese findings interest me because they also report difficulties. An average of self-reported time savings cannot fully describe what happens in a department. Time freed up may improve an answer, absorb additional demand or simply shift the workload to the person who knows the tool best. These effects do not have the same value for workers. I would therefore follow a complete activity, including rework and handovers. In customer service, for example, a faster first response is progress only if it prevents a further complaint or helps resolve the problem more effectively. This reasoning requires us to look beyond the production of text. It also means asking the people who receive the automated work for their views. Their experience often tells us more than a query counter, even when it contradicts the project’s initial story. |
BACK TO CONTENTS ↑ | | 04 | Microbusinesses and SMEs: five uses to try5 ITEMS · SOURCES AND DATES INCLUDED |
Proposed examples, not client deployments. Each trial specifies who does the work, who reviews it and what to measure. Sales: prepare a follow-up without inventing a promiseThe salesperson selects a quotation and its relevant history. AI drafts a follow-up; the salesperson checks prices, dates and commitments, then sends it themselves. Test ten cases and compare total time, corrections required and responses received. Do not share the entire mailbox when a few pieces of information are enough. Suggested trial: sales · Opera (27 Oct 2026) Administration: reconcile documents before payingThe administrator has references extracted from an invoice and a purchase order in an approved environment. AI flags discrepancies; a person checks amounts and bank details. No automatic payments during the trial. Measure correctly detected anomalies and false flags. Collective illustrates market interest in these tasks, within a different US tax context. Suggested trial: administration · Collective (29 Oct 2026, press release) Customer service: answer from an approved knowledge baseThe manager selects twenty frequently asked questions and their approved answers. AI prepares a draft with its source; the team handles requests outside the scope themselves. Measure accuracy, rework and complaints, not just response time. A request not covered by the documentation should receive no automatic answer. Suggested trial: customer service · Microsoft Research (30 Oct 2026) Recruitment: improve the advert before ranking peopleThe business owner describes the job’s actual tasks. AI helps clarify the advert; a person removes unnecessary criteria and checks their relevance. Begin without CVs or candidate data. Measure whether the applications received show a better understanding of the role. The next step, screening people, requires a different legal and organisational assessment. Suggested trial: human resources · CNIL, small businesses (30 Jan 2023) Meetings: retain the decision, not the whole conversationThe team decides in advance whether recording is necessary and under what conditions it is permitted. AI prepares an action list; participants correct ownership and deadlines. Plan access and deletion. The trial compares omissions and review time across a few meetings, without reusing people’s statements to assess them secretly. Suggested trial: coordination · NVIDIA (28 Oct 2026) · L1222-4 (since 2008) My perspective In a small business, a reasonable approach must remain workable on a busy Monday. I would start with a frequent, limited and reversible task whose result can be checked by the person who already performs it. An experiment becomes more informative when you know what you are prepared to stop if it disappoints. I also think the additional work needs counting. Cleaning documents, correcting responses and managing a subscription are not free activities. A business owner can estimate that cost simply, across a few cases, without building an elaborate measurement system. A good first experience produces two results: a useful service and a clearer understanding of its limits. If it produces only impressive text, without reducing rework or improving customer relationships, I would not yet consider the investment justified. |
BACK TO CONTENTS ↑ | | 05 | Technology: what changes for teams5 ITEMS · SOURCES AND DATES INCLUDED |
This week’s announcements are linked to operational choices. Vendor results remain explicitly attributed. IBM treats a model change as a software updateGranite Switch 4.1.1 updates speech recognition and routing components without retraining the entire base, according to IBM. The vendor says it is compatible with 4.1. For a technical team, the attraction is being able to improve a targeted capability; the claimed compatibility still needs testing against its own cases. Vendor announcement · IBM (29 Oct 2026) Liquid AI focuses on compact, specialised modelsLFM3 brings several modalities together around a shared base, with models of around two billion parameters. Liquid AI describes adaptation on a single GPU. This direction is relevant to local and specialised uses. It does not remove the need for suitable data or for testing errors against the company’s vocabulary and documents. Vendor announcement · Liquid AI (27 Oct 2026) Opera previews local AI in the browserWebAI lets websites and extensions use local models after the user enables them. Opera specifies hardware and operating-system restrictions. This is a preview, not a universal standard already deployed. Local processing reduces some transfers; it does not guarantee an extension’s safety or the appropriateness of its permissions. Preview announced on 27 October · Opera (27 Oct 2026) NVIDIA expands transcription, with details worth checkingNemotron 3.5 Transcribe announces 40 languages for transcription, but only 13 for speaker attribution. That detail matters when choosing a tool for multilingual meetings. Before buying or integrating it, test recordings representative of the noise, accents and vocabulary actually encountered. General capability does not replace this check. Vendor announcement · NVIDIA (28 Oct 2026) PROBE distinguishes a plausible bug from a priority bugThe preprint compares agents against a set of 2,457 bugs fixed by maintainers. Their discoveries overlap little with this reference set, although many are considered valid. The result invites a distinction between detection, relevance and prioritisation. It does not mean that every alert outside the reference set is false. Preprint, not an audit of your code · PROBE (26 Oct 2026, preprint) My perspective I would not choose an architecture solely on the basis of a model ranking. The vocabulary of the occupation, the documents available and access rights all influence the result substantially. Progress in smaller models and local execution opens up interesting options, but also transfers part of the operational work to the company. The next question is who will handle updates, regression testing and incident diagnosis. These are lasting responsibilities, rarely visible in a demonstration. Conversely, outsourcing operations to a remote service can simplify daily work while increasing contractual dependency. I prefer to compare these situations around a specific use, with criteria for quality and the ability to switch away. The discussion becomes less spectacular, but it helps identify a solution the team can actually maintain. |
BACK TO CONTENTS ↑ | | 06 | Costs and investment choices5 ITEMS · SOURCES AND DATES INCLUDED |
Assess returns at the level of completed work, including checking, operations and the ability to leave a service. Anthropic proposes looking at usage by teamThe new Claude Enterprise reports bring together activities, costs and difficulties, alongside group budgets. Anthropic says they are not intended for individual evaluation or employment decisions. That boundary is particularly relevant to our feature: an adoption dashboard should not quietly become an HR ranking tool. Vendor announcement · Anthropic (28 Oct 2026) Collective: distinguish equity from a growth facilityThe announced $100 million financing comprises a $40 million Series B and a $60 million growth facility. The service targets financial management for US self-employed workers. Claimed savings remain the company’s own figures. For a French microbusiness, checking the accounting and tax scope first would be more useful than comparing fundraising totals. Commercial press release · Collective (29 Oct 2026, press release) Ollie highlights the possible cost of leaving a serviceOllie has announced it will close on 6 November. My practical question: if your assistant stopped operating, could you export the data, resume the procedures and revoke its access? An exit test can be simple: reconstruct one case without the tool. The time required belongs in the supplier assessment. News and a management question · TechCrunch (30 Oct 2026) Agent commerce still needs evidence of useDoorDash reports only a few hundred orders from third-party agents. For a retailer, I would suggest first measuring the requests actually received through this channel. The existence of an integration is not enough to justify a new investment. Order errors, support requests and recovery costs need to be understood. News and proposed analysis · TechCrunch (30 Oct 2026) METR’s result should not become a sloganThe 2025 study found a 19% slowdown in a specific setting: experienced developers, familiar repositories and the tools of that time. In February 2026, METR explained that participant and task selection weakened its new protocol. The earlier figure cannot therefore serve as a general measure of current productivity. Two background studies, with distinct dates · METR, initial study (10 July 2025) · METR, follow-up (24 Feb 2026) My perspective A recurring difficulty in economic evaluation concerns the unit of measurement. A subscription is easy to count; a better-informed decision is less so. We may then take the available numbers, such as queries or documents produced, and treat them as evidence of value. This substitution deserves discussion with the teams involved. I would suggest a more modest calculation: how much does a correctly completed case cost, including checks and rework? Comparing a few situations before and after AI is introduced will not establish a universal truth, but it can inform a local decision. We also need room for benefits that do not immediately translate into time: better understanding, a more accessible answer, or fewer costly errors. Those benefits should be described and observed. Announcing them before measuring them would expose the project to the same weakness as the productivity promises it claims to replace. |
BACK TO CONTENTS ↑ | | 07 | Industry and work in the field4 ITEMS · SOURCES AND DATES INCLUDED |
The consequences of an error change when an AI output becomes an action in the physical world. RobotAgentBench examines recovery after failureThis benchmark examines autonomy in simulated domestic environments, including task discovery and error recovery. The authors find a gap between manipulation and autonomy. It does not validate an industrial robot. Its methodological value is to test behaviour after an incident, rather than only the successful completion of a planned sequence. Preprint; simulated domestic environment · RobotAgentBench (26 Oct 2026, preprint) Dream targets constructionDream has announced $17 million to develop world models for construction. For a construction project manager, the next question would be what has been tested on site, with which data and who is responsible if it fails. A funding announcement indicates a direction; it does not yet document an operational benefit. News and suggested questions · TechCrunch (29 Oct 2026) Maintenance: find an instruction and its versionSuggested trial: AI retrieves a procedure from an approved collection and identifies its reference and version. The technician checks the original document before intervening. The trial measures correct references retrieved and cases of abstention, using requests prepared with operators. No equipment adjustment is triggered automatically. Suggested trial: maintenance documentation · Microsoft Research (30 Oct 2026) A field demonstration should include interruptionSuggested trial: prepare a test with missing data or contradictory instructions. Check that the system asks for clarification and that the operator knows how to stop it. Record recovery time and the information available. This exercise does not replace the equipment’s safety assessment; it reveals some of the work required for oversight. Suggested trial: organisational testing · RobotAgentBench (26 Oct 2026, preprint) My perspective In field work, the gap between a suggestion and an action deserves particular attention. A documentary error can be corrected; a physical intervention operates on a different timescale and may involve safety. I think it is reasonable to begin by improving access to information and preparation for operations before extending a system’s autonomy. This caution does not rule out innovation. It helps establish what has actually been demonstrated. A simulation, a sales presentation and an on-site trial do not provide the same level of evidence. I would also ask operators which incidents the demonstration protocol leaves out: damaged equipment, contradictory instructions, unfamiliar surroundings. Their experience may improve the specification more usefully than another performance score. Finally, the authority to stop a system must be usable, understood and exercised in a trial before it is cited as a safeguard. |
BACK TO CONTENTS ↑ | | 08 | Ethics: the people behind the metrics5 ITEMS · SOURCES AND DATES INCLUDED |
Monitoring, explanation and the possibility of disagreement. Complaints remain allegations to be examined. Outlier: five complaints, not five findings of liabilitynoyb has announced five complaints against Scale AI in four European countries concerning worker monitoring and biometric checks. Scale disputes the allegations, The Record reports. The case concerns platform contractors and the GDPR. It is not a dismissal judgement under the AI Act, but it documents a current dispute over the conditions in which AI is produced. Complaints and the company’s response · noyb (27 Oct 2026, corrected on 29 Oct) · The Record (28 Oct 2026) An explanation should allow the result to be challengedIn Dun & Bradstreet Austria, the Court of Justice of the EU clarified that information about an automated decision should enable a person to understand and challenge its logic. The dispute concerned creditworthiness, not dismissal. It nevertheless illustrates a shared difficulty: providing an algorithm or invoking a trade secret is not enough to give the person concerned a useful explanation of a decision. Background case law · CJEU, C-203/22 (27 Feb 2025) A human click does not settle the automation questionArticle 22 of the GDPR governs decisions based solely on automated processing that have legal or similarly significant effects, subject to exceptions and safeguards. An organisation therefore needs to examine the actual role of the person who approves the output. Their name in the workflow does not, by itself, show that they exercised independent judgement. General legal analysis · GDPR, Art. 22 (applicable since 2018) A successful task can conceal a data leakLog-To-Leak studies prompt injection through MCP tool descriptions: an agent can complete the legitimate task and then transmit information without authorisation. This is an experimental result on specific configurations. For a company, it suggests checking secondary calls and data destinations as well as the visible quality of the response. Security preprint · Log-To-Leak (26 Oct 2026, preprint) Make room for disagreement during a pilotSuggested trial: provide a channel where people can report an error or reject an AI output without first having to defend the project. Name someone to examine reports and respond. Measure response time and whether corrections are made. An empty complaints register may mean everything works, or that nobody feels able to use it. Governance proposal · AI Act: Article 26 (consolidated 27 July 2026) My perspective Ethics becomes concrete when we ask what a person can do about a decision they do not understand. Can they access the information concerning them? Will an error be corrected before it has an effect? Will their disagreement be examined by someone with the necessary time and authority? These questions carry more weight than a general promise of responsible AI. I do not, however, think that every collection of data is illegitimate or every automation unfair. An organisation may need to verify access, prevent fraud or distribute a workload. The difficulty lies in justifying the means chosen, their proportionality and their secondary uses. A metric collected to improve a service can become something quite different if it is later used to penalise a person. That change of purpose, often gradual and barely visible, is what I would make systematically open to challenge within the project’s governance. |
BACK TO CONTENTS ↑ | | 09 | Policy and governance: preparing for the deadlines4 ITEMS · SOURCES AND DATES INCLUDED |
Debate over timing cannot replace work on responsibilities and the means of oversight. A postponement does not erase rules already in forceOn 1 November 2026, prohibitions on certain practices and AI literacy obligations have already started to apply, as have some transparency rules. The high-risk postponement suspends neither the GDPR nor national employment law. A roadmap should therefore separate actions due now from preparations for the next deadlines. Verified timetable · European Commission (19 Oct 2026) Training: an obligation now expressed more preciselyConsolidated Article 4 requires measures to develop AI literacy, taking people and context into account. It specifies that this does not require guaranteeing a particular individual level. A single generic training course is therefore not a universal certificate of compliance; the choice of measures and how they are adapted should be explainable. Consolidated text, not the earlier wording · AI Act: Article 4 (consolidated 27 July 2026) Employee consultation has its own timetableFrance’s Ministry of Labour sets out duties to inform and consult the CSE, the employee representative body, including on measures used to monitor work. Their application depends on the project and the company’s circumstances. Before deployment, management must examine this aspect with the appropriate parties; a European postponement does not automatically resolve it. French reference · French Ministry of Labour (accessed 1 Nov 2026) The history of an existing system must be documentedThe transitional provisions in Article 111 take account of when a system was placed on the market or put into service and, for certain systems, subsequent significant changes in design. The shorthand “every tool must change on the same day” is misleading. Keeping records of versions and purposes helps assess the situation with the supplier and legal advisers. Legal point to examine · AI Act: Article 111 (consolidated 27 July 2026) My perspective Postponing a deadline may have a practical justification: time to clarify standards, organise oversight or adapt products. It may also be read as a signal to wait. In my view, the useful distinction concerns what a company can already clarify without waiting for another guideline: its uses, its data and the people making decisions. I would also pay attention to how costs are distributed. Documentation requirements without support can weigh heavily on a small business, while poorly designed easing of the rules can leave affected people without an effective remedy. These tensions deserve precise discussion, rather than an abstract choice between innovation and regulation. A useful criterion is whether the arrangements allow meaningful experimentation while making it possible to account for a contested decision. That requires resources for implementation, not just a timetable. |
BACK TO CONTENTS ↑ | | 10 | Creative work and content production4 ITEMS · SOURCES AND DATES INCLUDED |
Make content more useful while preserving sources, editorial responsibility and the distinction between fiction and reporting. Informing the public: a rule with a defined scopeArticle 50 covers, among other things, certain AI-generated texts on matters of public interest. It provides an exception where content has undergone human review or editorial control and a person assumes responsibility for it. It neither requires labelling every assisted email nor permits publication without checking. Legal reference · AI Act: Article 50 (consolidated 27 July 2026) A fiction should be identifiable before it is readSuggested editorial practice: label a story “fictional case” at the outset and specify what is invented. For a legal example, separate the narrative from the texts used to analyse it. This discipline helps prevent a reader sharing an educational scenario as though it were a judgement or a documented client experience. Suggested editorial method · AI Act: Article 50 (consolidated 27 July 2026) Creating subtitles: check the meaning tooNVIDIA’s multilingual transcription can provide a starting point for subtitles. Suggested trial: have someone competent in the language review proper names, negatives and technical terms. Measure time saved after that review. A grammatically correct sentence may still contradict the original speaker. Suggested use for content · NVIDIA (28 Oct 2026) Test a summary before making it publicSuggested trial: ask AI to summarise three approved documents, then check every claim against its source passage. An editor decides what merits publication and retains the references. Record omissions as well as errors: a summary can be accurate sentence by sentence yet misleading because of what it leaves out. Suggested use: writing and verification · Microsoft Research (30 Oct 2026) My perspective The ease of producing coherent text does not remove the need for editorial judgement. It makes that judgement more important, because convincing wording can be obtained before the facts are established. For company communications, I would separate checking claims from editing style: these are different tasks, with different criteria. The fictional story in this edition follows that reasoning. It makes organisational decisions and their possible consequences visible; it should not borrow the authority of a court case that never happened. The same requirement applies to images, testimonials and client feedback. I prefer content that honestly explains what it shows to a more striking narrative whose status remains ambiguous. That transparency does not diminish the story’s interest. It lets the reader discuss the reasoning rather than having to guess what is true. |
BACK TO CONTENTS ↑ | THIS WEEK’S TUTORIAL Prepare a file for one AI use in 45 minutes45 minutes for an initial review, not to certify compliance | 01 Describe one situationChoose an existing or planned use. Write down what goes in, what the system produces and what a person decides afterwards. “We use an assistant” is too vague. “It ranks candidates before interview” gives you a starting point for analysis. 02 Start with the JDENIS checkerComplete the questionnaire using that situation. Keep the answers and the date. The result is indicative: it helps guide risk classification, not certify compliance. Any uncertainty about scope should remain visible. 03 Gather the documents you already haveCollect the supplier’s instructions, purpose, data categories, access arrangements, retention periods and versions. Note what is missing rather than having AI write it as though the practice already existed. A missing document is an action to address. 04 Identify the people affectedList affected employees, candidates, customers or contractors. With HR, the data protection officer and legal advisers as needed, examine information duties, lawful basis, any required consultation of the CSE employee representative body, and impact assessment where required. The questionnaire result alone does not settle these issues. 05 Test a contested decisionUse a fictional case containing an incorrect data item and a reasoned objection. The person providing oversight must be able to spot the error, request a check and stop the action. Keep the test result and the agreed correction. Avoid real personal data for this rehearsal. 06 Set the next decision pointRecord an owner, a deadline and a condition for continuing. For example: do not use the ranking for an employment decision until the identified issues are addressed. Have the scope reviewed by the appropriate professionals before a sensitive use. Your worksheetUse and purpose: People affected: Supplier, version and date of entry into service: Data and access: Proposed classification and uncertainties: Information and consultation required: Person overseeing the system and able to stop it: Available evidence / missing documents: Next check, owner and date: Open the AI Act checker ↗ | Help shape the next edition.Which decision in your work would be hardest to explain if AI had contributed to it? Reply directly to this newsletter. You can also request a topic, challenge an argument or describe a trial that did not work. I will gladly respond. For a sensitive situation, anonymise the people and company. I will not publish your feedback without your consent. Future editions may return to your questions, distinguishing your experience from any broader conclusions that can be drawn. Write to Jérôme ↗ | The connecting threadAI changes work, including what an organisation must be able to explain. The same thread connects an HR ranking, meeting minutes, a maintenance alert and a subscription expense: who examines the result, against which criteria, and with what opportunity to correct it? For the coming week, choose one decision supported by AI and try to reconstruct how it was reached. What is missing from that explanation is often a better starting point than another list of tools. | HELP SHAPE WHAT COMES NEXT Was this edition useful?One click is enough. I read every response. Very useful ↗Useful, but too long ↗Not for me ↗ | Who might find this newsletter useful?An HR manager, a small-business owner or a colleague supporting teams? Introduce them to SIGNAL AI and invite them to join the discussion. Subscribe to SIGNAL AI ↗ | SIGNAL AI #010 · Jérôme Denis · JDENIS Consulting 7 Bis Chemin de la Butte, 31400 Toulouse, France. General legal information, checked on 1 November 2026; the assessment of a particular case depends on its facts and the applicable law. Unsubscribe · Reply to Jérôme · Back to the top ↑ |
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