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EU AI Act · Regulation (EU) 2024/1689

Status 6 October 2026 · incl. Digital Omnibus

EU AI Act: overview, obligations and deadlines

The AI Act governs who may develop, offer and use AI in the EU – and under which conditions. Here you will find roles, risk classes, every obligation with its article and date, and a quick check that shows what applies to your company.

  • Every obligation with article and date
  • Deadlines after the Digital Omnibus
  • Quick check with matching resources
  • Sources on EUR-Lex
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AI Act status

Regulation (EU) 2024/1689

A
3/6
  • Prohibitions & AI literacy2 Feb 2025
  • GPAI models & penalties2 Aug 2025
  • Transparency (Art. 50)2 Aug 2026
  • New bans, marking legacy2 Dec 2026
  • High-risk AI (Annex III)2 Dec 2027
  • High-risk AI (Annex I)2 Aug 2028

Deadlines under Reg. (EU) 2026/1744

In short

What is the EU AI Act?

The EU AI Act (Regulation (EU) 2024/1689) is the EU law on artificial intelligence. It has been in force since 1 August 2024 and sorts AI systems by risk: some practices are banned, high-risk AI faces strict obligations, chatbots and AI content must be recognisable. Obligations phase in until 2028; every company using AI must already take AI literacy measures.

entry into force
1 Aug 2024
entry into force
risk classes plus rules for general-purpose AI
4 + GPAI
risk classes plus rules for general-purpose AI
high-risk AI under Annex III
2 Dec 2027
high-risk AI under Annex III
or 7% – top fine for prohibited practices
€35M
or 7% – top fine for prohibited practices

Basics

The EU AI Act in five sentences

A regulation, not a directive: the AI Act applies directly in every member state, without national transposition. National law mainly covers which authorities are responsible and how penalties are enforced.

The AI Act has two aims: to create a single market for trustworthy AI and to protect health, safety and fundamental rights from the risks of certain AI applications. It therefore does not regulate “AI” as a technology but specific purposes. A language model writing marketing copy is assessed differently from the same model pre-sorting job applications.

Under Article 3(1), an AI system is a machine-based system that operates with some degree of autonomy and infers from its inputs how to generate outputs such as predictions, content, recommendations or decisions. That covers not just models you build yourself but also purchased tools and AI features inside standard software – from the chat assistant in your office suite to lead scoring in your CRM.

Obligations depend on two questions: what is your role towards the system (mainly provider or deployer)? And which risk class does the specific use fall into? For most mid-sized companies the answer is “deployer” and “minimal or limited risk” – which leaves AI literacy, checking the prohibitions and, where relevant, transparency obligations. Anyone using AI in HR, credit decisions or products with safety functions carries considerably more.

With the Digital Omnibus (Regulation (EU) 2026/1744, in force since 27 July 2026) the EU adjusted the timeline: high-risk obligations under Annex III apply only from 2 December 2027, those under Annex I from 2 August 2028. At the same time, two new prohibitions were added that apply from 2 December 2026, and Article 4 was reworded.

Structure of the regulation

Chapter I
Subject matter, scope, definitions (Art. 1–3), AI literacy (Art. 4)
Chapter II
Prohibited practices (Art. 5)
Chapter III
High-risk AI: classification, requirements, operator obligations, conformity (Art. 6–49)
Chapter IV
Transparency obligations for certain AI systems (Art. 50)
Chapter V
General-purpose AI models – GPAI (Art. 51–56)
Chapters VI–IX
Innovation support, governance, EU database, post-market monitoring and market surveillance
Chapters XII–XIII
Penalties (Art. 99–101), final provisions and dates of application (Art. 111–113)
Annexes
incl. Annex I (product legislation), III (high-risk areas), IV (technical documentation)

Who is affected

Your role determines your obligations

The AI Act spreads obligations along the value chain. One company can hold different roles for different systems – provider for its own product, deployer for the HR tool it bought.

Provider

Art. 3(3)

Develops an AI system or model (or has it developed) and places it on the market or puts it into service under its own name – whether for payment or free of charge.

Main burden for high-risk AI: risk management, documentation, conformity assessment, post-market monitoring; Art. 50(1) and (2).

Deployer

Art. 3(4)

Uses an AI system under its own authority, except in a purely personal, non-professional activity. This is the typical role of companies buying AI tools.

AI literacy, Art. 26 for high-risk AI, Art. 27 where applicable; Art. 50(3) and (4).

Importer and distributor

Art. 23 · Art. 24

Importers place a third-country provider’s AI on the EU market; distributors make it available without being provider or importer.

Verify that conformity assessment, marking and documents are in place; do not place on the market if in doubt.

Authorised representative

Art. 22

Providers of high-risk AI without an establishment in the EU appoint an authorised representative in the Union by written mandate.

Keeps documents available for authorities and cooperates with them.

Product manufacturer

Art. 25(3)

Anyone placing a product under Annex I (e.g. machinery, medical device) on the market under its own name with a high-risk AI system as a safety component is considered the provider of that AI system.

Provider obligations for the AI system in the product.

GPAI provider

Art. 53 · Art. 55

Develops a general-purpose AI model (such as a large language model) and places it on the EU market.

Documentation, information for downstream providers, copyright policy, summary of training content.

Watch the role switch: when deployers become providers

Under Article 25(1), a deployer, distributor or importer takes on the full provider obligations for a high-risk AI system if it

  • puts its name or trademark on a high-risk AI system,
  • makes a substantial modification so that it remains high-risk, or
  • changes the intended purpose of a system that was not high-risk so that it becomes high-risk – for example using a general chat assistant specifically to pre-select job applications.

Scope and exemptions

Where the company is based is not decisive. What matters is whether AI is placed on the market or used in the EU.

Art. 2(1)
Providers outside the EU too. Covers third-country providers placing AI on the EU market, and providers and deployers in third countries where the system’s output is used in the Union.
Art. 2(3)
Military and national security. AI systems used exclusively for military, defence or national security purposes are excluded.
Art. 2(6)
Scientific research. Excluded are systems and models specifically developed and put into service for the sole purpose of scientific research and development.
Art. 2(10)
Purely personal use. Natural persons using AI in a purely personal, non-professional activity are not deployers under the regulation.
Art. 2(12)
Free and open-source licences. Largely excluded – but not if the system is placed on the market as high-risk AI or as a system under Article 5 or 50. For GPAI models, Article 53(2) applies.

Risk classes

Four risk classes and separate rules for general-purpose AI

The higher the risk a use poses to health, safety and fundamental rights, the stricter the rules. Classification is per use, not per product.

  1. 1Unacceptable risk – prohibited

    Art. 5

    Practices the EU considers incompatible with its values. Banned since 2 February 2025 with no transition period; two further prohibitions apply from 2 December 2026.

    Risk classification in detail

    Social scoring, manipulative techniques, exploiting vulnerabilities, emotion recognition at work and in education, untargeted scraping of facial images, biometric categorisation by sensitive traits.

  2. 2High risk

    Art. 6 · Annex I · Annex III

    AI as a safety component of regulated products (Annex I) or in eight sensitive areas (Annex III). Extensive obligations for providers and deployers, from 2 December 2027 and 2 August 2028 respectively.

    All Annex III areas

    Recruitment and performance evaluation, creditworthiness, risk and pricing in life and health insurance, access to education, critical infrastructure, biometrics.

  3. 3Transparency risk

    Art. 50

    People should be able to tell when they are interacting with AI or looking at AI content. Applies since 2 August 2026.

    Labelling under Article 50

    Chatbots, AI-generated images, audio and video, deepfakes, AI text on matters of public interest, emotion recognition.

  4. 4Minimal risk

    Art. 95 (voluntary)

    No specific AI Act obligations. Voluntary codes of conduct are possible; AI literacy under Article 4 still applies.

    Document the classification

    Spam filters, translation aids, text suggestions, search features, AI in video games, stock forecasts.

  5. 5General-purpose AI models

    Art. 51–55

    Separate obligations for providers of large models, across the risk classes. Since 2 August 2025; models placed on the market before then have until 2 August 2027.

    GPAI obligations

    Large language, image and multimodal models. Stricter rules for systemic risk, presumed above 10^25 FLOPs of training compute (Art. 51(2)).

One system can fall into several categories at once: a chatbot that pre-sorts applications is high-risk and must also be recognisable as AI.

Obligations overview

Every EU AI Act obligation: article, addressee, date

The table sums up the key obligations, grouped by topic. Dates reflect the Digital Omnibus. For high-risk AI: 2 December 2027 for Annex III, 2 August 2028 for Annex I.

Scroll the table sideways →

Every EU AI Act obligation: article, addressee, date
ObligationArticleWhoFromResource
For all companies
Take measures to support the AI literacy of staff and persons acting on your behalfArt. 4Providers, deployers2 Feb 2025 (reworded 27 Jul 2026)Training record
Refrain from prohibited practicesArt. 5(1)all operators2 Feb 2025Risk classes
New prohibitions: non-consensual intimate deepfakes of identifiable persons, child sexual abuse materialArt. 5 (Omnibus)all operators2 Dec 2026Digital Omnibus
Overview of the AI systems in use (no express obligation, but a prerequisite for any classification)Recommendationall companiesrecommended nowAI register
Transparency
Inform people that they are interacting with an AI system (e.g. chatbot)Art. 50(1)Provider2 Aug 2026Article 50
Mark synthetic content in a machine-readable formatArt. 50(2)Provider2 Aug 2026; systems before 2 Aug 2026: by 2 Dec 2026Article 50
Inform people about emotion recognition or biometric categorisationArt. 50(3)Deployer2 Aug 2026Article 50
Disclose deepfakes and AI text on matters of public interestArt. 50(4)Deployer2 Aug 2026Article 50
High-risk AI: providers
Check classification; for the Art. 6(3) exception document the assessment and registerArt. 6 · Art. 49(2)Providerwith Annex III obligationsAnnex III
Risk management system across the entire lifecycleArt. 9Provider2 Dec 2027 / 2 Aug 2028Checklist
Data and data governance (training, validation, test data)Art. 10Provider2 Dec 2027 / 2 Aug 2028Checklist
Technical documentation under Annex IVArt. 11Provider2 Dec 2027 / 2 Aug 2028Documentation
Enable automatic loggingArt. 12Provider2 Dec 2027 / 2 Aug 2028–
Transparency and instructions for use for deployersArt. 13Provider2 Dec 2027 / 2 Aug 2028–
Design for human oversightArt. 14Provider2 Dec 2027 / 2 Aug 2028–
Accuracy, robustness and cybersecurityArt. 15Provider2 Dec 2027 / 2 Aug 2028–
Quality management system (proportionate for SMEs)Art. 17Provider2 Dec 2027 / 2 Aug 2028Governance
Keep documentation for 10 yearsArt. 18Provider2 Dec 2027 / 2 Aug 2028–
Conformity assessment, EU declaration of conformity, CE markingArt. 43 · 47 · 48Provider2 Dec 2027 / 2 Aug 2028–
Registration in the EU databaseArt. 49 · Art. 71Provider (Annex III, except point 2)2 Dec 2027–
Post-market monitoringArt. 72Provider2 Dec 2027 / 2 Aug 2028–
Report serious incidents, at the latest 15 days after becoming aware (shorter in severe cases)Art. 73Provider2 Dec 2027 / 2 Aug 2028Incidents
High-risk AI: deployers
Use according to the instructions; oversight by competent, trained peopleArt. 26(1)–(2)Deployer2 Dec 2027 / 2 Aug 2028Checklist
Check input data against the intended purpose, monitor operation, report risks and incidentsArt. 26(4)–(5)Deployer2 Dec 2027 / 2 Aug 2028–
Keep automatically generated logs for at least 6 monthsArt. 26(6)Deployer2 Dec 2027 / 2 Aug 2028–
Inform workers’ representatives and staff before use at the workplaceArt. 26(7)Deployer (employer)2 Dec 2027 / 2 Aug 2028–
Data protection impact assessment using the provider’s informationArt. 26(9)Deployer2 Dec 2027 / 2 Aug 2028–
Inform people when Annex III systems make or assist decisions about themArt. 26(11)Deployer2 Dec 2027–
Fundamental rights impact assessmentArt. 27public bodies, private providers of public services, Annex III point 5(b)/(c)2 Dec 2027–
On request, explain the AI system’s role in a decisionArt. 86Deployerwith Annex III obligations–
Own brand, substantial modification or new purpose: full provider obligationsArt. 25Deployers, distributors, importers2 Dec 2027 / 2 Aug 2028–
General-purpose AI models
Technical documentation, information for downstream providers, copyright policy, summary of training contentArt. 53GPAI provider2 Aug 2025; legacy models by 2 Aug 2027–
Additionally for systemic risk: model evaluation, risk mitigation, incident reporting, cybersecurityArt. 55GPAI provider with systemic risk2 Aug 2025; legacy models by 2 Aug 2027–

“2 Dec 2027 / 2 Aug 2028”: Annex III and Annex I respectively. High-risk AI intended for public authorities and placed on the market earlier has until 2 August 2030 (Art. 111(2)). Simplified; the text of the regulation prevails.

Quick check

What applies to my company?

Six questions, one list: the quick check shows which AI Act obligations most likely apply to your company, since or from when – and where to find the matching template or guide. No sign-up, nothing stored.

Question 1/6
How do you work with AI?

This is about your role towards the AI systems. It can differ from system to system.

app.simpleact.de

Your result

EU AI Act · VO (EU) 2024/1689

A

Answer the questions on the left – your list of obligations appears here.

Simplified guidance, not legal advice. Classification depends on the specific use and has to be checked per AI system.

Deadlines

The EU AI Act timeline after the Digital Omnibus

The regulation has been in force since 1 August 2024 and its obligations apply in stages. Since 2 August 2026 it applies in principle in full – with the postponed exceptions for high-risk AI.

  1. Applies

    Entry into force

    The regulation enters into force and the transition periods begin.

  2. Applies

    Prohibitions and AI literacy

    Prohibited practices under Art. 5 and AI literacy under Art. 4 apply.

  3. Applies

    GPAI, governance, penalties

    Obligations for providers of general-purpose models, authority structures and the penalty framework.

  4. Applies

    Digital Omnibus in force

    New deadlines for high-risk AI, Art. 4 reworded, relief for SMEs.

  5. Applies

    General application and Art. 50

    Transparency obligations apply; the Commission can impose GPAI fines.

  6. Upcoming

    New bans, marking for legacy systems

    Two new prohibitions; systems placed before 2 Aug 2026 must mark content under Art. 50(2).

  7. Upcoming

    Legacy GPAI, sandboxes

    Deadline for models placed on the market before 2 Aug 2025; national AI regulatory sandboxes.

  8. Upcoming

    High-risk AI under Annex III

    Obligations for providers and deployers in the eight Annex III areas.

  9. Upcoming

    High-risk AI under Annex I

    AI as a safety component of regulated products such as machinery or medical devices.

All deadlines with deadline finder and calendar

High-risk AI

High-risk AI: what providers and deployers must deliver

A system is high-risk if it is a safety component of a product under Annex I or falls into one of the eight Annex III areas. For Annex III systems there is an exception under Article 6(3) – for example for narrow procedural tasks or purely preparatory work. It never applies where the system profiles natural persons.

Providers

Risk managementArt. 9
An ongoing process that identifies, evaluates and mitigates risks – not a one-off document.
Data governanceArt. 10
Training, validation and test data must be fit for purpose, as error-free and representative as possible; possible biases are examined.
Technical documentationArt. 11 · Annex IV
Describes system, development, data, performance, limits and oversight. After the Omnibus, SMEs and small mid-caps may use a simplified form.
LoggingArt. 12 · Art. 19
The system records events automatically; providers keep the logs under their control.
Transparency and oversightArt. 13 · Art. 14
Instructions for use for deployers; a design that allows effective human oversight – including intervening and stopping.
Accuracy and robustnessArt. 15
An appropriate level of accuracy, robustness and cybersecurity across the lifecycle.
Quality managementArt. 17
Documented procedures for development, testing, changes and incidents – proportionate to company size.
Conformity and registrationArt. 43 · 47 · 48 · 49
For Annex III points 2–8 internal control under Annex VI, for point 1 possibly a notified body. Then declaration of conformity, CE marking and entry in the EU database.
After placing on the marketArt. 72 · Art. 73
Monitor performance on the market, report serious incidents to market surveillance.

Deployers

Use as intendedArt. 26(1)
Technical and organisational measures so the system is used in line with its instructions for use.
Human oversightArt. 26(2)
Assign oversight to people with the necessary competence, training and authority, and support them.
Input data and monitoringArt. 26(4)–(5)
Where input data is under your control, check it against the purpose; monitor operation and inform the provider or authorities of risks or incidents.
LogsArt. 26(6)
Keep automatically generated logs, where under your control, for at least six months.
Inform staffArt. 26(7)
Before putting into service at the workplace, inform workers’ representatives and affected workers.
DPIA and affected peopleArt. 26(9) · (11)
Use provider information for the data protection impact assessment; inform people about whom the system makes or prepares decisions.
Fundamental rights impact assessmentArt. 27
For public bodies, private providers of public services and deployers under Annex III point 5(b) and (c) (credit, life and health insurance).
Explanation of decisionsArt. 86
Affected people can request a clear and meaningful explanation of the AI system’s role in decisions with significant effects.

In practice for deployers: before buying a high-risk tool, clarify which documents the provider supplies (instructions for use, declaration of conformity, information for the DPIA) – a procurement recommendation, not a separate obligation.

GPAI

General-purpose AI: obligations for model providers – and what they mean for users

General-purpose AI (GPAI) models perform a wide range of tasks and can be built into many downstream systems – typically large language models.

The Chapter V obligations fall on model providers, not on companies using a model via an API or a finished tool. Since 2 August 2025, providers must keep technical documentation, give downstream providers the information they need for their own obligations, put in place a policy to comply with EU copyright law and publish a summary of the training content using a template from the AI Office (Art. 53(1)).

Models with systemic risk – presumed when training required more than 10^25 floating-point operations – are additionally subject to Article 55: model evaluation including adversarial testing, assessing and mitigating systemic risks, reporting serious incidents and adequate cybersecurity. Free open-source models benefit from relief under Article 53(2), but not where there is systemic risk.

Supervision of GPAI providers lies with the European Commission’s AI Office. Since 2 August 2026 the Commission can impose fines on GPAI providers (Art. 101). Models placed on the market before 2 August 2025 must comply by 2 August 2027.

What this means for companies using GPAI

  • No GPAI provider obligations as long as you only use the model or integrate it into your own applications.
  • Your system built on top follows the normal rules: role, risk class, Article 50.
  • The provider information under Article 53 helps with your own documentation – ask for it.
  • AI literacy under Article 4 also applies to using chat assistants.
AI Act documentation

Digital Omnibus

What the Digital Omnibus changed

Regulation (EU) 2026/1744 was published in the Official Journal on 24 July 2026 and has been in force since 27 July 2026. The key changes compared:

Scroll the table sideways →

What the Digital Omnibus changed
TopicBeforeSince the Omnibus
High-risk AI under Annex IIIfrom 2 Aug 2026from 2 Dec 2027
High-risk AI under Annex Ifrom 2 Aug 2027from 2 Aug 2028
AI literacy (Art. 4)ensure a “sufficient level”, to their best extenttake measures to support it
Marking AI-generated content (Art. 50(2))from 2 Aug 2026 for all systemssystems before 2 Aug 2026: by 2 Dec 2026
Prohibited practices (Art. 5)eight prohibitionsplus: non-consensual intimate deepfakes, child sexual abuse material – from 2 Dec 2026
Registration for the Art. 6(3) exceptionregistration in the EU databasestill required, simplified procedure
SMEs and small mid-capsrelief for SMEsextended: simplified technical documentation, proportionate QMS
National AI regulatory sandboxesby 2 Aug 2026by 2 Aug 2027

Unchanged: prohibitions since 2 Feb 2025, GPAI obligations since 2 Aug 2025, Art. 50 from 2 Aug 2026, fines under Art. 99.

Digital Omnibus in detail

Penalties

Fines under Article 99

The AI Act tiers fines by severity. The higher amount applies in each case – except for SMEs and start-ups, for which the lower amount applies (Art. 99(6)). Since the Digital Omnibus, this also applies to small mid-caps (Art. 3(14b)), but only for fines under paragraphs 4 and 5 (Art. 99(6a)).

Percentages refer to total worldwide annual turnover of the preceding financial year. When setting a fine, authorities consider among other things the nature, gravity and duration of the infringement, intent or negligence, measures to mitigate damage and cooperation with the supervisor.

Article 4 (AI literacy) has no fine tier of its own in Article 99. Missing training can still weigh in with other infringements – and in practice it is often why infringements happen at all. Companies that document the measures they took are in a much better position with supervisors.

Member states set the procedures and designate the market surveillance authorities. The Commission is responsible for GPAI providers; since 2 August 2026 it can impose its own fines (Art. 101).

prohibited practices under Art. 5
€35M / 7%
prohibited practices under Art. 5
incl. Art. 16, 22–26, 31, 33, 34 and 50
€15M / 3%
incl. Art. 16, 22–26, 31, 33, 34 and 50
incorrect or misleading information to authorities
€7.5M / 1%
incorrect or misleading information to authorities

AI Act and GDPR

AI Act and GDPR work together

The AI Act does not replace the GDPR. As soon as an AI system processes personal data both apply – with different focuses: the GDPR protects data, the AI Act regulates the product and its use.

DPIA and fundamental rights impact assessment

Deployers of high-risk AI use the provider’s information for their data protection impact assessment under Article 35 GDPR (Art. 26(9)). The fundamental rights impact assessment under Article 27 can refer to an existing DPIA.

Automated decisions

Article 22 GDPR limits solely automated decisions with legal effect. The AI Act adds human oversight (Art. 14, Art. 26) and the right to an explanation (Art. 86).

Records and register

The record of processing activities under Article 30 GDPR and the AI register can be linked: every AI processing of personal data belongs in both – with different mandatory fields.

Processing on behalf

External AI services that process personal data on your behalf usually need a contract under Article 28 GDPR; for providers outside the EU, Article 44 et seq. apply as well.

Implementation

Implementing the AI Act in six steps

The order that has proven itself in practice. It is a recommendation – the regulation does not prescribe a procedure.

  1. 01

    Record your AI systems

    Collect all AI systems you use or build in one register, with purpose, vendor, department, owner and data concerned – including AI features in standard software.

    AI register template (Excel)
  2. 02

    Determine role and risk class

    For each system, record whether you are provider or deployer and document the risk class with reasons. Expressly rule out the Article 5 prohibitions.

    Risk classification
  3. 03

    AI literacy and policy

    Introduce an AI policy for employees and plan role-based training – with a record of who completed what and when.

    AI policy (Word template)
  4. 04

    Implement transparency

    Review chatbots, generated content and deepfakes and build in notices and marking. The deadlines are already running.

    Article 50 decision tree
  5. 05

    Anchor governance

    Set responsibilities, an approval workflow for new AI tools and review intervals so the register stays current.

    AI governance framework
  6. 06

    Prepare high-risk obligations

    For high-risk systems, build documentation, oversight, logs and conformity by 2 December 2027 (Annex III) or 2 August 2028 (Annex I).

    High-risk checklist

Time needed varies widely. From a pilot project: six AI systems, one of them high-risk, were recorded and assessed in around four hours.

Resources

Every guide, template and tool on the EU AI Act

Each page goes deeper into one topic of this overview – with tables, downloadable templates and interactive tools.

With SimpleAct

How SimpleAct supports implementation

Every obligation hangs off the same record: the captured AI system. That keeps classification, documentation and evidence consistent.

  • Basis for every obligation

    Know which AI is in use

    Without a complete overview you can neither determine the risk class nor show which obligations apply. Purchased tools and AI features in standard software count too.

    In SimpleAct

    AI inventoryAI Discovery from Professional

    Every AI system in one place: vendor, purpose, affected areas and responsible person per system. Find shadow AI with AI Discovery.

    Go to AI inventory
  • Art. 5 · Art. 6 · Annex III

    Determine the risk class

    Every system belongs to a risk class. That decides which obligations apply at all.

    In SimpleAct

    Risk classification

    Rule-based classification through a structured questionnaire – with a reasoned result and the requirements that follow from it.

    Go to risk classification
  • Art. 11 · Art. 26 · Art. 27

    Maintain documentation

    Providers document under Annex IV, deployers their Article 26 obligations and, where applicable, the fundamental rights impact assessment.

    In SimpleAct

    Documentation & checklists

    Annex IV documentation or deployer obligations, plus compliance checklists per risk class, right on the captured system.

    Go to documentation
  • Art. 14 · Art. 26 · Art. 17

    Accountability and approvals

    Responsibilities, oversight and traceable decisions are the core of any AI Act organisation.

    In SimpleAct

    GovernanceProfessional and up

    Governance workflows and audit readiness score: owners, reviews and approvals per system.

    Go to AI governance
  • Evidence for supervisors

    Evidence for review and audit

    Reviewers want to see what was decided, by whom and when – not just the current state.

    In SimpleAct

    Audit log & export

    Changes logged with user and timestamp, evidence exportable for reviews.

    Go to audit & export
  • Art. 4

    Support AI literacy

    Providers and deployers take measures on their staff’s AI literacy.

    In SimpleAct

    AcademyEnterprise

    Training and e-learning on AI literacy across the team.

    Go to the Academy

PDF guides and templates

Free PDF downloads – orientation, checklists and templates on the EU AI Act.

FAQ

Frequently asked questions about the EU AI Act

The EU AI Act is Regulation (EU) 2024/1689 on artificial intelligence. It entered into force on 1 August 2024, applies directly in all member states and regulates AI systems by risk: from prohibited practices to high-risk AI to transparency obligations. Since July 2026 it has been amended by the Digital Omnibus (Regulation (EU) 2026/1744).
In stages: prohibitions and AI literacy since 2 February 2025, rules for GPAI models, governance and penalties since 2 August 2025, general application and Article 50 transparency obligations since 2 August 2026. High-risk AI under Annex III follows on 2 December 2027, high-risk AI under Annex I on 2 August 2028.
Yes. Anyone using AI professionally under their own authority is a deployer. Since February 2025 all deployers are subject to Article 4 (AI literacy measures) and the prohibition of certain practices. Depending on the use, transparency obligations under Article 50(3) and (4) and, for high-risk AI, the deployer obligations under Article 26 are added.
Yes, if they place AI on the market or put it into service in the EU, or if the output of their AI system is used in the Union (Art. 2(1)). Providers of high-risk AI without an EU establishment must appoint an authorised representative in the Union (Art. 22).
Usually not. The purpose decides: for writing, research or summaries there is generally no high-risk status, though Article 4 and possibly Article 50 apply. If the same assistant is used specifically for recruitment or performance evaluation, the use can fall under Annex III – and under Article 25 the company may even become the provider.
The AI Act does not expressly require companies to keep an internal AI register. Without an overview, however, role, risk class and obligations cannot be determined or evidenced. A register is therefore the usual first step. This is different from the EU database under Articles 49 and 71, where providers of high-risk AI and public authorities as deployers register systems.
Up to €35M or 7% of worldwide annual turnover for prohibited practices, up to €15M or 3% for breaches of obligations including Articles 16, 22–26 and 50, up to €7.5M or 1% for incorrect information to authorities. For SMEs, including start-ups, the lower amount applies (Art. 99(6)). Since the Digital Omnibus, this also applies to small mid-caps (Art. 3(14b)), but only for fines under paragraphs 4 and 5 (Art. 99(6a)).
Regulation (EU) 2026/1744 has been in force since 27 July 2026. It moves high-risk obligations under Annex III to 2 December 2027 and under Annex I to 2 August 2028, rewords Article 4 (“take measures to support”), gives legacy systems until 2 December 2026 for marking under Article 50(2), introduces two new prohibitions from 2 December 2026 and extends relief for SMEs and small mid-caps.
Providers and deployers take measures to support the AI literacy of their staff and other persons working with AI on their behalf – taking into account prior knowledge, context of use and affected people. Since the Omnibus, no particular level has to be guaranteed. Common measures are a policy, role-based training and a record of attendance.
Providers develop an AI system or have it developed and place it on the market under their own name (Art. 3(3)). Deployers use an AI system under their own authority (Art. 3(4)). Most high-risk obligations fall on providers; deployers have the obligations under Article 26 and, where applicable, Article 27.
When it is a safety component of a product under Annex I that requires third-party conformity assessment (Art. 6(1)), or falls into one of the Annex III areas (Art. 6(2)) – such as employment, education, creditworthiness or critical infrastructure. An Annex III system is exceptionally not high-risk if it poses no significant risk and meets one of the conditions in Article 6(3); the exception never applies to profiling.
Partly. Providers of generative systems must mark content in a machine-readable way (Art. 50(2)). Deployers must disclose deepfakes and label AI text published to inform the public on matters of public interest as AI-generated – unless it has undergone human review with editorial responsibility (Art. 50(4)). This applies since 2 August 2026.
Member states designate national competent authorities, in particular market surveillance authorities (Art. 70). For GPAI models, the European Commission’s AI Office is responsible. Which authority is competent in your case depends on national implementing law and partly on the sector.
No. The page is for guidance and is maintained by the SimpleAct editorial team. For binding assessments of your specific AI systems, involve your legal or compliance team. The text of the regulation in its current version prevails.

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Sources and status

Last checked on · SimpleAct editorial team

This page is for guidance only and is not legal advice. Tables and the quick check simplify; the text of the regulation in its current version prevails.

Changes to this page

  • 10 October 2026 – Art. 4 in the Omnibus wording, entry into force on 1 Aug 2024 and staged application clarified.
  • 6 October 2026 – Rebuilt and merged with the former “EU AI Act Compliance” page: obligations table with article and date, “What applies to my company?” quick check, roles and scope, GPAI, Omnibus comparison, 14 FAQs.
  • 27 July 2026 – Deadlines updated for the Digital Omnibus (Annex III from 2 Dec 2027, Annex I from 2 Aug 2028, Art. 4 reworded).

Open-Source Framework

simpleact-ai-act-compliance-guide

Open-source EU AI Act compliance guide: obligations per risk class, deadlines, article mapping, and implementation guidance.

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From overview to a maintained AI register

SimpleAct records your AI systems, assigns roles, risk classes and obligations and links them to your GDPR documentation – in one system, hosted in Germany.