TESSA: A Governance-Oriented Custom GPT for SME Guidance under the EU AI Act: Design, Implementation, and Evaluation

The EU AI Act (Regulation 2024/1689) imposes technical obligations on high-risk AI providers, yet Articles 8-15 were drafted for predictive AI and leave seven technical gaps when applied to generative systems, spanning non-deterministic data governance, training-data provenance, continuous conformity, human oversight, open-ended robustness, emergent risk, and generative fairness. We deliver Governance-as-Code (GaC), a framework of 43 machine-checkable acceptance criteria across six compliance modules that run in a CI/CD pipeline and emit Article-indexed audit evidence, and we show the actual Rego policy code rather than merely describing it. Our central commitment is that the Act's open-textured standards ("appropriate levels," "possible biases") become declared, auditable numbers: robustness thresholds are derived from the provider's documented baseline and a state-of-the-art floor, and framing bias is collapsed into eight measurable proxies tested by counterfactual demographic probing. We also correct who owes what, since under Article 25 and Chapter V a downstream deployer relies on the upstream provider's Article 53 training-data summary and documents only the layers it controls, so GaC verifies that summary rather than demanding per-sample documentation the deployer never had. We validate on two enterprise deployments, a high-risk advisory chatbot and a limited-risk content generator, benchmarking against a manual expert audit rather than documentation artifacts that were never designed to enforce compliance. GaC reproduces all of the manual audit's findings, including three penalty-triggering violations, while cutting audit labor by roughly 75%.

Turkey's e-Government Gateway (e-Devlet) serves over 68 million registered users with more than 9,200 government services, and is increasingly integrating artificial intelligence into citizen-facing applications such as chatbot assistants and eligibility assessments. However, no structured technical governance infrastructure currently connects high-level AI policy frameworks, such as the EU AI Act, OECD AI Principles, and Turkey's own National AI Strategy, to the operational reality of deploying AI within a centralized e-government platform. We propose GovAI-Pipe, a four-layer governance pipeline designed using Design Science Research methodology that maps the AI model lifecycle to governance checkpoints: (1) pre-deployment validation for bias testing, explainability, and privacy impact assessment; (2) deployment governance for risk-tier classification and approval workflows; (3) runtime monitoring for drift detection, fairness tracking, and human-in-the-loop escalation; and (4) post-incident governance for audit trails, rollback, and citizen redress. Each layer is anchored to specific provisions of the EU AI Act, the GDPR data protection framework, and the National AI Strategy. We demonstrate the framework through two high-risk e-Devlet use cases, showing how GovAI-Pipe operationalizes governance principles as auditable, technical pipeline components.

The EU AI Act introduces extensive compliance requirements for organizations that develop, deploy, or integrate AI systems. Many of these requirements are directly relevant to security and privacy, while also addressing closely related issues such as data governance, transparency, accuracy, and robustness. However, stakeholders such as small-to-medium businesses and individual developers often lack the legal expertise required to interpret these obligations and translate them into engineering and governance practices. This disconnect creates challenges for implementing the EU AI Act and may lead to missing safeguards or misdirected development and deployment efforts. To address this, various automated EU AI Act compliance checkers (AIACCs) have emerged, claiming to streamline compliance assessments and provide practical guidance. In this paper, we present the first empirical study and assessment of AIACCs. We characterize 12 mainstream AIACCs across multiple dimensions, evaluate their legal coverage and alignment, and analyze checker-generated compliance reports for structure, determinacy, and actionability. We find that the quality of AIACCs varies significantly and that they currently can only serve as early-stage orientation tools. Specifically, we observe inconsistent interaction modes and user-friendliness, a tendency to overly simplify or omit key obligations, and a failure to provide determinate, actionable guidance. As a result, reliance on the current generation of AIACCs may foster a false sense of compliance. With our study, we provide a critical baseline of the current AIACC landscape. We further offer design principles for the implementation of more reliable compliance-support tools.