The Act's phased design — prohibitions first, high-risk obligations next, transparency requirements to follow — was presented as regulatory pragmatism. What the implementation record now shows is that early compliance numbers tracked the easy requirements: member states could claim progress by acknowledging the law existed without building the institutional machinery to apply it. The gap between legislative adoption and operational readiness is not a temporary lag — it is the predictable outcome of a governance model that delegated enforcement to member states without conditioning that delegation on demonstrable capacity. The…