What is new
Contract First extends the single-deployer Article 10 mapping (v1.0.0) with the multi-entity joint deployer pattern. Single-deployer YAML breaks the moment a subsidiary runs a platform the parent procured. v1.1.0 ships the structure that handles it.
Added
contracts/energy_balance_v0.5_multi_entity.yaml— joint deployer reference contract withdeployer_arrangement, per-entity Article 3(8) authority analysis, and Article 26 obligation matrixdocs/multi-entity-pattern.md— full pattern document covering the dilution problem, the CJEU analogy (C-210/16, C-25/17, C-40/17), the four-block composable pattern, SQL implementation, three twelve-month failure modes, and limitations.github/ISSUE_TEMPLATE/multi_entity_correction.md— issue template for joint-deployer YAML corrections- README "Multi-Entity Implementation" section with CJEU triology reference
Changed
- Regulatory timeline corrected throughout repository: Annex III enforcement 2 December 2027 (extended from 2 August 2026 via Digital Omnibus), Annex I enforcement 2 August 2028
- Narrative shifted from "August 2026 enforcement" to "runway not relief" framing
- CITATION.cff bumped to 1.1.0 with multi-entity keywords
Legal grounding
The joint deployer doctrine rests on three CJEU joint controllership cases applied by analogy: Wirtschaftsakademie Schleswig-Holstein (C-210/16), Jehovah's Witnesses (C-25/17), and Fashion ID (C-40/17). The principle survives translation: authority plus decision rights equals joint deployer status under AI Act Article 26.
Audience
Senior architects at group structures preparing the multi-entity case. Privacy and compliance officers who need technical artifacts not policy PDFs. Consultants building governance practices for mid-market clients with subsidiary structures.
Not legal advice
The CJEU analogy is doctrinal reasoning, not a substitute for qualified counsel review of a specific organisational structure. Consult a qualified lawyer for AI Act compliance opinions.