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Disclaimer

Project: Pickles GmbH — AI Governance Framework Version: v1 Date: 2026-02-28

The Pickles GmbH AI Governance Framework is an educational and demonstration resource. It does not constitute legal advice, regulatory guidance, or a compliance certification of any kind.

Nothing in this framework should be relied upon as a substitute for advice from a qualified lawyer with expertise in EU AI Act, GDPR, German data protection law, or the professional conduct rules applicable to your organisation.

Pickles GmbH Does Not Exist

Pickles GmbH is a fictional company created for the purpose of demonstrating how an AI governance framework might be structured for a German legal AI provider. All company characteristics, system descriptions, personnel references, and scenarios in this framework are entirely fictional.

Vertrag.AI, referenced in the Phase 2 worked example, is also fictional. No actual contract review tool, AI system, or legal AI product is described or implied.

This Is a Framework Proposal, Not a Compliance Certification

This framework represents one approach to structuring AI governance documentation under the EU AI Act, GDPR, BDSG, and BRAK professional standards. It has not been:

  • Reviewed or approved by any regulatory authority
  • Reviewed by a qualified German lawyer
  • Tested against any real company's actual systems or data
  • Certified as meeting any specific compliance standard

Compliance with the EU AI Act, GDPR, or any other regulation requires assessment of your specific systems, operations, and context by qualified professionals. This framework cannot and does not make that assessment for you.

Regulatory References

Regulatory references in this framework (EU AI Act articles, GDPR provisions, BDSG sections, BRAK guidelines) were made in good faith based on source documents available at the time of drafting. They do not constitute authoritative legal interpretation.

The EU AI Act and related guidance are subject to ongoing development. Provisions, timelines, and obligations may have changed since this framework was produced. Always verify regulatory content against current official sources before relying on it.

Assumptions

This framework was built on a set of unverified assumptions about the fictional Pickles GmbH company. Every document flags these assumptions using the marker [ASSUMPTION]. A complete list is maintained in ASSUMPTIONS-LOG.md.

Before this framework is adapted for operational use by a real organisation, every assumption must be validated against actual company data, systems, and practices.

Limitation of Liability

The author of this framework accepts no liability for any loss, damage, regulatory action, or other consequence arising from the use, adaptation, or reliance on any part of this framework.

Licence

This framework is published under CC BY 4.0. You are free to use and adapt it, but you do so at your own risk and responsibility. Attribution is required.

If you are considering using this framework operationally, please engage a qualified lawyer before doing so.