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Scope obligations and assign owners

After classification, confirm which derived obligations genuinely apply, mark the rest not applicable, put a named owner on each, and settle your Art. 4 literacy duty.

Updated 15.07.2026

Once a system is classified, the engine derives its obligation set and the journey moves into the Scope & literacy phase (phase 2 of 6). Scoping is a short but important pass: you confirm which derived obligations genuinely apply, put a named owner on each, and settle your Art. 4 AI-literacy duty — before the heavy implementation work begins.

Where the applicable obligations show up

The obligations the engine generated appear in two places, both live views of the same records:

  • On the system — as the tab bar across the system page. Each tab groups the obligations for one area (e.g. Transparency, Human oversight, Supply chain); the bar only shows tabs your system actually has.
  • Across the portfolio — on the Obligations board, the cross-system view of every obligation by status.

Open any obligation to see its detail drawer: the article reference, its in-force date, the checklist, evidence slots and audit history.

Confirm what applies

  1. Open the system and read down the tab bar — this is the full set the engine derived from your classification and behavioural flags.
  2. Open each obligation. Read the article reference and description to confirm it fits how you actually use the system.
  3. If an obligation genuinely does not apply, set its status to Not applicable in the drawer. This is a scoping call, not a completion claim — the score simply excludes it, and there's no four-eyes gate on it. Leave a note so the de-scoping decision is auditable.
  4. Leave everything that does apply at To do for now — you'll work through it in the Implement phase.

Tip: don't mark obligations Complete during scoping to "clear" the phase. The gate wants genuine completion. De-scope only what truly doesn't apply.

Assign owners

Accountability is per obligation. Open the obligation, use the Assigned to control in the header to pick a team member (choose Unassigned to clear it), and optionally set a Due date so the item surfaces on the Calendar and in the dashboard action queue as it approaches. You can also set an initial Owner for the whole system at registration, and manage owners in bulk from the Obligations board. Owners receive the reminders the platform sends, so an unassigned obligation is one nobody is watching.

Art. 4 AI literacy sits in this phase

The Scope phase is labelled Scope & literacy because it also carries your Art. 4 duty (in force since 2 Feb 2025) to ensure staff who build or use AI have sufficient literacy. This is an organisation obligation — you satisfy it once for the tenant, not once per system. See AI literacy: satisfying Article 4.

Gate-locking

A phase is complete when every applicable obligation in it is complete — or when it has no applicable obligations (then it's vacuously complete). A later phase is LOCKED while any earlier, non-empty phase is below 100%. The 6-dot journey bar shows it: complete phases green, the current phase amber, a locked phase greyed with a tooltip naming what's blocking it. See The six-phase compliance journey.

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