Most enterprise AI deployments run on foundation models or AI services from third parties, OpenAI, Anthropic, Azure AI, AWS Bedrock, and others. Each of those is an ICT third-party relationship under DORA, a data processor relationship under GDPR, and potentially a supply-chain consideration under the EU AI Act.
The gap usually isn't the contracts; most organizations have updated vendor agreements by now. It's the operational documentation: a clear map of which AI agents depend on which external services, what data those services receive, and what the fallback is if a service is unavailable. That belongs in the ICT third-party register, and it should be reviewed whenever the AI deployment changes.
Why it maps to regulation: DORA Article 28 requires a register of ICT third-party arrangements. GDPR Articles 28 and 44 to 49 require processing agreements and transfer mechanisms for any processor handling personal data. EU AI Act Article 26 places obligations on deployers of high-risk AI systems, including using the system according to its instructions and monitoring its operation, which in practice requires knowing which foundation model or service an agent actually depends on.
WEM implementation: An external service call inside a WEM No-Code workflow, over SOAP, REST/JSON, OData, or RAW HTTP, is explicit in the workflow definition itself, which gives a third-party mapping exercise a starting point that matches how the system actually runs, rather than a separate document that drifts out of sync with it.