EU AI Act compliance: what applies to your AI system, and on which date

Published: 2026-11-02 · Updated:

Most teams start EU AI Act compliance in the wrong place. They buy a policy template, or a scanning tool, before they have decided what role they play under the regulation — and the role decides everything that follows. A team that places a system on the EU market and a team that uses one internally do not have the same duties, the same dates, or the same paperwork. This is the checklist we run before we scope any compliance engagement in the EU: find the role, find the classification, then find the date.

What EU AI Act compliance actually covers

Regulation (EU) 2024/1689 applies to systems placed on the EU market or put into service in the Union, and to the people who place them there. Compliance is not one obligation. It is a set of obligations that depends on two decisions: the role you play, and the classification of the system.

Both decisions are checkable against the instrument itself, and the instrument is public. The EU AI Act Explorer carries the regulation article by article, including Annex III; the Commission’s regulatory framework page carries the guidance and the dates. If a summary you were given does not match the instrument, the instrument wins — and that rule is worth more than any checklist, ours included.

Step one: find your role

Four roles decide the duties. A provider develops the system or has it developed and places it on the market under its own name or trademark. A deployer uses it under its own authority, in a professional capacity. An importer brings a system into the Union, and a distributor passes one on. Most teams are a provider and a deployer at once — for two different systems, or for the same system at two points in its life.

The role is the cheapest hour of work in the whole engagement, because it decides which of the remaining questions you have to answer at all. Answer it before you buy anything.

Which obligations are already in force

Three sets are already with you, and none of them wait for 2027:

From 2 August 2026 the Article 50 transparency duties for synthetic content apply, with no grace period for systems placed on the EU market on or after that date. The four-month grace period ending 2 December 2026 applies only to systems already on the EU market before 2 August 2026. If your team has been treating the Act as a 2027 project, this is the date to correct first.

What changes on 2 December 2027

If the system is high-risk under Annex III, the Chapter III Sections 1–3 duties apply from 2 December 2027: risk management (Art. 9), data governance (Art. 10), technical documentation (Art. 11), record-keeping (Art. 12), transparency (Art. 13), human oversight (Art. 14), and accuracy, robustness and cybersecurity (Art. 15). Article 72 post-market monitoring sits with them.

Two dates, two very different kinds of work. The 2026 obligations are mostly labelling and disclosure. The 2027 obligations are an operating system of evidence: a risk management process, a data trail, a documentation set that stays true as the code changes, and a monitoring plan for what happens after release. A team that starts in 2027 with nothing is buying a documentation retrofit. A team that starts now is building the trail it will need.

One caveat on planning: the dates have already moved once, and the guidance is still moving with them. A trail built as artefacts, checks and versioned evidence absorbs a change in scope or timetable as a version bump rather than as a rewrite of the compliance folder.

The evidence a compliance file has to hold

This is the test a buyer can apply without reading the regulation: ask to see the file. For one high-risk system it should hold a technical file to Annex IV, a conformity assessment, an Article 49 registration entry for the EU database, a deployer-information pack, and a post-market monitoring plan.

Two questions decide whether the file is real. First: can it be produced on demand, from the system as it runs today, rather than assembled for an audit? Second: does every artefact point at evidence you already produce — a commit, a test run, a log line — rather than at a document somebody wrote once and nobody has revisited since? The second question is what separates a trail from a folder.

What to automate, and what to leave to a person

Compliance work is not a document project. A large part of it is the same class of work we do for back-office teams: a rule decides, a model proposes, a named person confirms.

Where that work sits, and how a fixed first milestone around it is scoped, is described on our EU AI Act compliance service page.

Questions to ask before you buy help

Six questions that separate a compliance partner from a template shop.

  1. Which role do we play for each system, and where is that recorded?
  2. What is the classification of each system under Annex III, and who signed it off?
  3. Can the technical file be produced from the running system, today, with no audit in progress?
  4. What is in scope for the first milestone, what is explicitly out of scope, and what is the success metric?
  5. What happens when the guidance changes — is the trail versioned?
  6. Who owns the decision when a classification is contested?

If a supplier cannot answer the third question, they are selling documents, not a trail. The process page is the version of this we run ourselves, the security page is the default posture we ship, and the trust index lists the artefacts a procurement or DPO team asks for.

Questions teams ask

Is the EU AI Act compliance deadline 2027?

Partly. Three sets of obligations are already in force: the prohibited AI practices and the AI-literacy duty, both since 2 February 2025, and the general-purpose AI model obligations since 2 August 2025. The Article 50 transparency duties for synthetic content apply from 2 August 2026, with no grace period for systems placed on the EU market on or after that date. What lands on 2 December 2027 is the Annex III high-risk duty set for systems classified as high-risk.

Do we need this if we only use AI tools?

Usually as a deployer rather than a provider, and yes, some of it applies to you. Using a system under your own authority in a professional capacity makes you a deployer, and the AI-literacy duty since 2 February 2025 reaches the people operating it. What you do not get as a deployer is the provider’s technical documentation and conformity assessment — but you do get the duty to use the system according to the instructions, to inform affected people, and to keep a log where the provider asks for one.

What documentation do we actually have to keep?

For a high-risk system: a technical file to Annex IV, a conformity assessment, an Article 49 registration entry for the EU database, a deployer-information pack and a post-market monitoring plan. The useful test is not whether the folder exists but whether it can be produced on demand from the system as it runs today, with every artefact pointing at evidence you already produce — a commit, a test run, a log line.

Can a tool do this for us?

The mechanical half, yes. Classification against the instrument, the system inventory and continuous evidence collection are rule-shaped, frequent and checkable, which is exactly what automation is good at. The judgement does not transfer: whether a system is high-risk under Annex III, whether a control is adequate and whether a residual risk is acceptable stay with a named person. We build and operate the EU AI Act Scanner for the mechanical half, and client work runs the same method against your system, your data and your evidence.

One classification is a better first step than a compliance programme.

One system, one role, one classification, written down and signed before any code ships. Here is that unit filled in for a single AI system.

  1. The first step Classify one system: the role you play with it, its purpose, the inputs it touches, and the Annex III classification that follows — signed and dated, with the reasoning written down next to it.
  2. The metric The share of your systems that carry a recorded role and a recorded classification. It is the number that says the programme started, and it is the denominator every later obligation is drawn against.
  3. The out-of-scope list What this first milestone deliberately does not cover.
    • Classification of every other system
    • The technical file to Annex IV
    • Conformity assessment and Article 49 registration

We take on a limited number of contracts each year. If your paragraph names the system, the metric and what you would leave out, one reply can tell you whether it’s a fit.

Reply within one business day, from the person who writes the code.