Gaps in AI-Compliant Complementary Governance Frameworks' Suitability (for Low-Capacity Actors), and Structural Asymmetries (in the Compliance Ecosystem) - A Systematic Review

Abstract

This review examines AI governance centered on Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (the EU Artificial Intelligence Act), alongside comparable instruments (ISO/IEC 42001, NIST AI RMF, OECD Principles, ALTAI). Using a hybrid systematic–scoping method, it maps obligations across actor roles and risk tiers, with particular attention to low-capacity actors, especially SMEs and public authorities. Across the surveyed literature, persistent gaps emerge in enforceability, proportionality, and auditability, compounded by frictions between the AI Act and GDPR and fragmented accountability along the value chain. Rather than introducing a formal model, this paper develops a conceptual lens—compliance asymmetry—to interrogate the structural frictions between regulatory ambition and institutional capacity. This framing enables the identification of normative and operational gaps that must be addressed in future model design.