With the adoption of the AI Act, the European Union has sent a powerful signal: artificial intelligence is a powerful technology that carries too many risks to be run without clear governance in place within organizations. To reinforce accountability, the Act points to the creation of a dedicated compliance role: the AI Officer. While this position, sometimes referred to as Chief AI Officer or Artificial Intelligence Officer, is not imposed as a legal obligation, the EU frames it as a forward-looking best practice for companies that build, integrate, or deploy AI tools. In practice, it is expected to become a hallmark of strong corporate governance in the years ahead.
The concept mirrors a familiar compliance trajectory. Just as data protection rose to board-level prominence after the GDPR, AI oversight is now moving into the spotlight of strategic decision-making. The AI Officer’s mandate will be broad and demanding, supervising the full lifecycle of AI systems, from design and testing through documentation and deployment, identifying risks and ensuring they are addressed, and acting as the link with regulators and auditors.
Yet this function is far more than a technical assignment. The EU’s approach recognizes that responsible AI is not simply about algorithms or engineering. It is about embedding accountability into corporate culture, aligning risk management with ethical considerations, and ensuring legal compliance with evolving regulatory standards. For companies, appointing an AI Officer is less about ticking a box and more about signaling readiness to meet regulatory expectations, and readiness to earn trust from clients, partners, and the broader public.
Later, we will examine how this emerging position compares to the now-established Data Protection Officer (DPO) role under the GDPR, which transformed compliance practices across Europe. But first, we turn to the AI Officer itself: its regulatory foundations, its scope of authority, and the practical challenges businesses will face in making the role a reality.
AI Officer: A Regulatory Pathway to Trustworthy AI
The EU’s AI Act introduces more than technical requirements – it also encourages organizations to rethink how compliance is structured internally. One of the central elements of this vision is the recommendation to appoint an AI Officer, a role designed to oversee and coordinate adherence to the Act’s obligations.
While not required by law, naming an AI Officer is strongly recommended for all organizations, and is particularly significant for providers and deployers of high-risk AI systems. These are contexts where artificial intelligence may significantly affect individuals’ rights, health, safety, or access to essential services. In such areas, from recruitment and education to medical decision-making and the operation of critical infrastructure, the EU’s regulatory message is clear: when AI has the potential to reshape people’s lives, organizations should entrust its oversight to a dedicated compliance professional.
The logic follows a familiar regulatory pattern. Just as the EU previously introduced designated officers for data protection, the AI Act reflects the principle that compliance cannot be an afterthought or a dispersed responsibility across departments. Instead, accountability must be embedded in corporate governance, with centralized expertise ensuring independence, consistency, and long-term vigilance.
By establishing the AI Officer role, the EU signals that trustworthy AI depends on ongoing supervision, from design and testing through deployment and monitoring, to keep systems aligned with fundamental rights and societal values throughout their lifecycle.
Turning Risk into Accountability: Key Duties of the AI Officer
The introduction of the AI Officer role under the EU AI Act reflects a broader shift in how artificial intelligence is governed. Rather than leaving responsibility scattered across technical teams, the Act emphasizes the need for a single point of accountability within organizations. The AI Officer embodies this principle by bridging law, ethics, and technology, ensuring that compliance becomes an integral part of corporate governance. In particular, the AI Officer is expected to take on a set of key responsibilities:
- Identifying and Managing Risks
AI systems can affect fundamental rights, safety, and access to essential services. The AI Officer is expected to map risks across the lifecycle of AI systems, from design to deployment, and ensure mitigation strategies are in place. This means proactively assessing where AI may cause harm and implementing safeguards before problems arise.
- Supervising Compliance Processes
Much like the Data Protection Officer under the GDPR, the AI Officer provides ongoing oversight of compliance activities. This includes verifying that AI systems meet the AI Act’s requirements, from transparency and documentation obligations to post-market monitoring duties.
- Acting as a Liaison with Regulators
The AI Officer also plays a communication role, serving as the organization’s contact point for supervisory authorities, auditors, and stakeholders. By centralizing this responsibility, organizations can ensure consistency in their regulatory interactions.
- Embedding Accountability into Governance
Beyond legal compliance, the AI Officer contributes to shaping organizational culture. The role signals that trustworthy AI is not just a technical matter but a business-wide priority. By fostering awareness, training staff, and ensuring alignment between departments, the AI Officer helps create a culture of accountability.
This new compliance role highlights a growing reality: AI governance is moving from the margin to the center of strategic decision-making. The AI Officer is not simply a monitor of technical processes but a steward of trust, ensuring that innovation develops within a framework of legal certainty and societal responsibility.
The AI Officer Within the Organization
This is no ceremonial title: the AI Officer is meant to carry real weight inside the company. For compliance oversight to work, the EU AI Act insists the role must combine independence with authority – and that makes its position within the hierarchy decisive.
1. Independence is the starting point. Like the Data Protection Officer under the GDPR, the AI Officer must be able to exercise judgment without interference or undue pressure from management. This does not mean working in isolation, but it does require freedom from conflicts of interest.
2. Resources are equally vital, as independence without support is meaningless. To fulfill their mandate, the AI Officer must have access to technical experts, legal advisors, testing tools, and adequate staff capacity. The Act intentionally leaves the standard of “adequate” open-ended, recognizing that resources will need to scale depending on the size of the company and the scope of its AI systems.
3 .Connection to the top management is the third pillar. The Officer must be able to raise concerns directly with senior decision-makers, ensuring compliance issues are treated as strategic priorities rather than buried within middle management. In this way, the AI Officer becomes both an operational overseer and an advisor within the company’s governance structure.
The Unique Competencies of an AI Officer
What sets the AI Officer apart is the interdisciplinary nature of the role. Unlike traditional compliance functions that are primarily legal or purely technical, this position demands a blend of law, technology, and ethics.
1. Legal and regulatory expertise – The Officer must master the obligations of the AI Act – from risk management and conformity assessments to transparency duties and regulatory interactions. Crucially, they must be able to translate abstract legal norms into concrete corporate processes.
2. Technical competence – The role also requires fluency in the mechanics of AI systems: how models are trained, validated, and monitored. While not expected to write code, the Officer needs to communicate effectively with engineers and data scientists, ask critical questions, and spot compliance vulnerabilities.
3. Ethical sensitivity – Beyond technical and legal aspects, the Officer must weigh broader principles such as fairness, non-discrimination, and transparency. Their responsibility extends to ensuring that systems not only function properly but also align with fundamental rights and values.
As this hybrid skillset is rare, organizations may need to recruit professionals with cross-disciplinary backgrounds – lawyers who understand machine learning, engineers with compliance experience, or specialists trained directly in AI governance. Over time, we are likely to witness the emergence of a distinct professional track: compliance leaders styled as AI Officers or even Chief AI Officers, positioned at the forefront of digital governance.
Practical Challenges in Establishing an AI Officer
Although the AI Officer is conceived as a forward-looking role, turning the concept into practice will be far from simple. For organizations, the real challenge is not just naming an AI Officer but dealing with the broader hurdles that come with the role.
- Defining “adequate resources”: The AI Act intentionally leaves this standard open-ended, recognizing that the needs of a multinational deploying multiple high-risk systems will differ from those of a smaller provider with a single product. Yet this flexibility creates uncertainty: What level of budget is sufficient? How many staff should support the Officer? How robust must testing infrastructure be? Until regulatory practice and guidance evolve, companies will need to make their own informed judgments.
- Closing the talent gap: The role requires a rare blend of legal, regulatory, and technical expertise. In a market where such profiles are scarce, companies may struggle to recruit. Early solutions may include building in-house training programs, drawing on external consultants, or experimenting with shared or outsourced AI Officer models.
- Managing overlaps with existing functions: Many organizations already assign compliance responsibilities to Chief Compliance Officers, Chief Information Security Officers, or Ethics Committees. The AI Officer’s remit may intersect with these functions, raising questions about reporting lines and accountability. Without careful planning, this could result in duplication, conflict, or gaps where no one takes responsibility.
- Embedding the role in company culture: For the AI Officer to succeed, they must be seen not as a bureaucratic hurdle but as a strategic partner. This requires strong support from senior leadership, open collaboration with technical teams, and a commitment to weaving AI governance into everyday business practices.
Comparison of the AI Officer and the DPO
When discussing AI governance under the EU framework, comparisons between the Data Protection Officer (DPO) under the GDPR and the emerging AI Officer under the AI Act are inevitable. Both are internal compliance functions, created by EU law to embed accountability, structure, and regulatory engagement within organizations. To make the comparison clearer, here is a side-by-side overview of where the DPO and the AI Officer align – and where they diverge.
Aspect | DPO (GDPR) | AI Officer (EU AI Act) |
Legal foundation | Obligatory role under GDPR. | Not compulsory under the AI Act, but recommended as good practice. |
When appointed | Required for public bodies and in cases of large-scale personal data use. | Voluntary – organizations may designate one to handle AI Act compliance. |
Scope of work | Safeguarding personal data and ensuring GDPR compliance. | Overseeing AI governance broadly, covering ethics, risks, and non-personal data. |
Independence | Legal guarantees of independence with dismissal protection. | No statutory safeguards, independence is determined internally. |
Reporting line | Must report directly to senior management. | Suggested best practice: report to compliance or risk leadership structures. |
Primary functions | Ensure GDPR compliance, conduct DPIAs, and interact with DPAs. | Manage risk assessments, documentation, and monitoring, and liaise with AI regulators. |
Training focus | Raising staff awareness on data protection obligations. | Promoting AI literacy and training operators on responsible AI use. |
Regulatory interface | Supervisory data protection authorities (DPAs). | Market surveillance authorities and, in some cases, the European Commission. |
Sanctions | Fines apply if an organization fails to appoint a DPO when legally required. | No penalty for not appointing, but sanctions apply for breaching AI Act obligations instead. |
Beyond the table, it is worth looking more closely at the principles that unite the two roles, and the important differences that set them apart.
a) Shared Foundations
Their similarities reflect the EU’s common regulatory design principles.
- Independence – both must operate free from conflicts of interest and without management interference.
- Resourcing – each role requires sufficient budget, expertise, and staff to perform effectively.
- Direct access to leadership – they report directly to senior management to ensure compliance issues are addressed at the highest level.
- Regulatory link – DPOs act as the bridge to data protection authorities, while AI Officers interact with market surveillance authorities and notified bodies.
Both positions also support risk assessments, policy development, staff training, internal reporting, and serve as external contact points. In short, the EU has applied a familiar compliance model: a dedicated officer role backed by resources and independence, with accountability built into corporate governance.
b) Key Differences in Scope
Yet, beneath these parallels, their mandates and expertise diverge sharply.
- Mandatory vs. recommended: The DPO is a legal requirement under the GDPR, whereas the AI Officer is not compulsory under the AI Act, but strongly recommended, particularly for providers of high-risk AI systems.
- Focus areas: The DPO’s mandate is narrowly tied to personal data — overseeing GDPR compliance, safeguarding rights, managing DPIAs, ROPAs, subject requests, and breaches. Their profile is often rooted in law, compliance, and IT security.
- Broader remit of the AI Officer: The AI Officer’s scope extends beyond personal data to cover non-personal datasets, AI system classification, conformity assessments, technical documentation, monitoring, and even ethical considerations such as fairness and transparency. This requires technical literacy and ethical awareness, in addition to legal knowledge.
Dual-Hat Roles: Efficient or Risky?
Could one person act as both DPO and AI Officer? In smaller companies or startups, where resources are limited, the option may seem attractive. There are efficiencies: shared regulatory knowledge, streamlined reporting, and reduced expenses.
However, the risks are real. Overload is one concern, but so are conflicts of interest. For instance, if an AI system processes personal data, the same person would need to assess compliance under two distinct legal frameworks – GDPR and the AI Act, which could lead to conflicting compliance assessments.
For most organizations, keeping the functions separate will better preserve independence and focus. The overlap between the two roles becomes most apparent when AI systems process personal data. In such cases, close cooperation between the DPO and AI Officer is essential to ensure coherent compliance strategies. Yet, even here, the knowledge bases remain distinct enough that expecting one individual to fully cover both roles is unrealistic.
The takeaway is clear: while the AI Officer borrows its structural DNA from the DPO, it represents a new profession in its own right. It is an inherently cross-functional role, positioned at the intersection of law, technology, and ethics, and is set to become one of the defining compliance specializations of the coming decade.
