Method guide

AI governance for SMEs: the Route in 30 days

From not knowing which AI you use to being able to show it. Seven steps, one document per step.

Where do I start?

What the Route is

The Route is a working method for an SME to govern the AI it uses. It does not explain the law: the law is in the AI Act guide. Nor is it the tool: the tool is in the features. The Route is the how, in order: what you do first, what you decide next and which document is left once each step is done.

The order is not arbitrary. Without an owner, nobody decides; without an inventory, you do not know which systems anything applies to; without your organisation’s role for each system, you do not know which obligations are yours and which are the provider’s; and without classification, you do not know how much work each one needs. Policies, training and evidence all rest on what comes before.

The 30 days are the work plan, not a legal deadline. They are designed for an SME that puts in a few hours a week, with steps overlapping where they can: while you wait for a vendor’s documentation, you draft the policy. Obligations have their own dates, and each chapter says which one is its own.

If you would rather read it week by week, here is the same Route told week by week.

What each feature does

Who it is for

  • SMEs that use third-party AI: a writing assistant, a chatbot on the website, management software that comes with AI features.
  • Anyone who has received a questionnaire on AI use from a large client and needs to answer it with documents, not intentions.
  • The person who has been made answerable for AI without a legal team behind them.
  • Companies starting from scratch that want a clear order before buying anything.

Who it is not for

  • Anyone who develops and places high-risk AI systems on the market: provider obligations are different, and this guide does not cover them.
  • Anyone looking for a seal that says their company is in order. The Route produces dated, reviewable documents, not seals.
  • Anyone who needs a legal opinion on a specific case. The guide organises the work; it is not a substitute for legal advice.

What you will have at the end

A name in writing and seven documents, each with its date and its author. Together they are what you can show when someone asks how you govern AI.

  • Step 0, the starting step · A name in writing: who is answerable for AI in your company, with their scope, their deputy and who they report to.
  • Step 1 · The AI systems inventory, in its first version.
  • Step 2 · Your organisation’s role for each system, with the reasoning in writing.
  • Step 3 · The classification record: level, reasoning, date and author of each decision.
  • Step 4 · A file per vendor, with the questionnaire and the documentation received.
  • Step 5 · The AI use policy, adopted and communicated, with read acknowledgements.
  • Step 6 · The record of Article 4 AI literacy measures.
  • Step 7 · The evidence file and a status report that summarises it.

The Route at a glance

The AI governance Route for SMEs: step 0 and the seven stepsA starting step 0 and seven steps in a vertical line, from 1 to 7, each with the document it leaves: the owner’s designation, the inventory, the role per system, the classification record, the file for each vendor, the use policy, the AI literacy record and the evidence file. The last step is highlighted: it brings the documents from the earlier steps together in a file that can be shown.THE ROUTE · ONE DOCUMENT PER STEPFrom a named owner to evidence that can be shown0Who is responsibleWritten designation: scope, deputy and reporting line1The inventoryAI systems inventory, first version2The role per systemYour organisation’s role for each system, with reasoning3Classifying the riskClassification record: level, reasoning, date and author4The vendorsFile per vendor: questionnaire and documentation5The use policyAI use policy, communicated, with read acknowledgements6AI literacyRecord of Article 4 AI literacy measures7The evidenceEvidence file and status reportWhat you can show:the documents from every step, in one fileA working method, not a legal requirement: each chapter states the nature of its step
The Route: the starting step 0 and the seven steps. Each chapter explains why its step exists, how it is done and which document it leaves.

Which step are you on?

A few short questions on how your company uses AI and what you have documented. At the end you know which step to start with and what you can skip because it is done.

Take it with you as a PDF

The whole Route in one document, with the starting step 0, the seven steps and the template for each, to work on offline or share with whoever has to help you.

Download the Route as a PDF

Get it by email

One step per email, in the Route’s order, so that you keep moving without having to remember to come back.

Get the Route by email

Seven emails, one per step, in the order of the guide. Each one summarises its chapter and links the template. The emails are written in Spanish.

I want to receive by email The Route, the free Alethexis course: seven emails on AI governance for SMEs, spread over approximately 25 days. I can cancel the emails at any time
I also want to receive the Alethexis newsletter, with content on artificial intelligence, regulation and news about its products and services. I can unsubscribe at any time

Data protection — email course

Controller: ALETHEXIS, S.L. (NIF B88758057). Purpose: To handle your request and send you the seven emails of The Route course. If you also tick the newsletter box, to send you periodic content on artificial intelligence, regulation and Alethexis news. Legal basis: Your consent (Article 6(1)(a) GDPR), given separately for each purpose. You may withdraw it at any time without affecting the lawfulness of processing carried out before its withdrawal. Recipients and transfers: we use providers acting on behalf of Alethexis for hosting, security and email delivery. No disclosure of your data to third parties for their own purposes is planned, except where required by law. Some providers may process data outside the EEA with the safeguards set out in the additional information. Rights of access, rectification, erasure, objection, restriction and portability: [email protected]. You may lodge a complaint with the Spanish Data Protection Authority (AEPD, www.aepd.es) or with the supervisory authority of your Member State (Article 77 GDPR). More information in the privacy policy.

Additional information: the course, the newsletter and how to unsubscribe

The Route course: seven emails on AI governance for SMEs, sent over approximately 25 days from when you confirm your enrolment. You receive it because you ticked its box. You can cancel it with the "Darse de baja del curso" (unsubscribe from the course) link in every email, which is written in Spanish: that stops only the course.

Alethexis newsletter: only if you tick its box. Periodic content on artificial intelligence, regulation and Alethexis news, with a consent independent of the course. You can unsubscribe with the link in every newsletter: that stops the newsletter and any other commercial communication from Alethexis, but does not cancel the course.

Unsubscribe from everything: the "Darse de baja de todo" (unsubscribe from everything) link in every course email stops the course, the newsletter and any other commercial communication from Alethexis, and records your unsubscription so that they do not resume.

For each box you tick we keep the date, the language, the version of the text you accepted and the origin of the request. Enrolling only in the course does not subscribe you to the newsletter.

Retention: Unconfirmed requests will be deleted after 14 days. Confirmed enrolments will be kept for as long as necessary to manage the course. Once it has ended or been cancelled, we may keep, for an ordinary maximum of 24 months from its end or unsubscription, the minimum data necessary to evidence the consent, its confirmation and, where applicable, its withdrawal, unless there is a legal justification for a different period. If you ask to stop receiving commercial communications, we will keep the minimum information necessary to respect your decision

Frequently asked questions

Are the 30 days a legal deadline?

No. They are the guide’s work plan, designed for an SME that puts in a few hours a week. The obligations under Regulation (EU) 2024/1689 have their own dates, which are in the AI Act timeline; the Route organises the work so that you reach them with the documents done.

Which part of the Route is a legal obligation and which is not?

Each chapter says so in its “Why” section, with its nature spelled out in words. Two examples from either end: Article 4 has required measures to support the development of AI literacy among staff since 2 February 2025 and, as worded since 27 July 2026, it is an obligation of means, not of result; the AI owner in step 0, on the other hand, is an internal methodological control, because the Regulation does not require one to be designated.

Do I need a tool to follow it?

No. The Route can be followed with documents and a spreadsheet, and each step comes with its template. What a tool changes is maintenance: keeping the inventory, the decisions and the evidence connected when something changes, with their date and their author.

What if one of my systems is high-risk?

The Route is the foundation, not the end. The deployer obligations in Article 26 apply from 2 December 2027 for Annex III high-risk systems and from 2 August 2028 for Annex I systems; it does not reach products under Section B of Annex I. The fundamental rights impact assessment applies from 2 December 2027 if your organisation falls within the scope of Article 27(1). Separately, the data protection impact assessment (Article 35 GDPR) is required where the processing calls for it, whatever the classification of the system. They are independent instruments.

How is it different from the article on the first 30 days?

It is the same method told another way. The article tells it week by week; the guide orders it by step, with a chapter for each and the document it produces.

The law, in detail

The Route points to the articles where needed, but it does not explain them one by one. That is what the AI Act guide is for: what it is, who it applies to, the risk levels and the dates.

Read the AI Act guide

Dates under Art. 113 of Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744 (OJEU of 24 July 2026, in force since 27 July 2026). This content is informational and is not legal advice.