FAQEU

EU AI Act Common questions, clear answers

Start with what your AI does and whether you build, supply or use it. Then check its risk category, duties and deadlines.

These answers explain the main decisions and link to the legal sources. Use the detailed FAQs for conditions, exceptions and evidence.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 21, 2026
6 sections15 primary sources10 FAQ modules
Overview

The AI Act answer depends on the system or model, its intended use and your role. The questions below cover scope, risk classification, duties and dates, followed by staff literacy, individual rights and support for smaller organisations.

Browse sub-FAQs

Choose the question set you need

These focused FAQ modules break this artifact into narrower answer sets so teams can move straight to the right source-backed guidance.

Browse all FAQ items41
Focused FAQ modules
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Showing 10 of 10
FAQ module

Are you the provider or the deployer? | EU AI Act

Check provider, deployer, importer and distributor roles, when changes create provider duties, and how model and system responsibilities differ.

5 items
FAQ module

Do you need a notified body? | EU AI Act

Find the assessment route for high-risk AI, when a notified body is required, and which declaration, CE-marking and registration records you need.

4 items
FAQ module

Does this tool count as AI? | EU AI Act

Check whether software counts as AI, how models differ from systems, when embedded AI is high-risk, and which scope and role evidence to keep.

4 items
FAQ module

How do you monitor AI after release? | EU AI Act

Understand high-risk AI monitoring under Article 72: the provider plan, deployer feedback, logs, corrective action, incidents and change reviews.

4 items
FAQ module

Is this industry use high-risk? | EU AI Act

See which industry AI uses fall under Annex III, when Article 6(3) can apply, and what providers must document and register.

4 items
FAQ module

What belongs in the technical file? | EU AI Act

See what Article 11 and Annex IV require in high-risk AI technical documentation, from system identity and testing to monitoring and retention.

3 items
FAQ module

What must general-purpose model providers do? | EU AI Act

Check general-purpose model duties, systemic-risk classification, open-source conditions, copyright, training summaries, incidents and application dates.

5 items
FAQ module

When must you disclose AI use? | EU AI Act

Check AI interaction notices, technical content marking, biometric notices, deepfake and text disclosures, exceptions, accessibility and deadlines.

6 items
FAQ module

When must you report a serious incident? | EU AI Act

Check serious-incident outcomes, reporting roles, 15-, 10- and two-day deadlines, authority recipients, corrective action and the separate model route.

3 items
FAQ module

Who needs a rights impact assessment? | EU AI Act

Check who needs an Article 27 fundamental rights impact assessment, what it must cover, and how privacy assessments, notification and registration fit.

3 items
Question 1

Does the Act apply, and what is your role?

Check the EU connection and your role first. You can provide one AI system, use another as a deployer, and build a downstream system with someone else's general-purpose model. Articles 2 and 3 define the scope and roles.

The 2026 amendment changed the high-risk dates. Chapter III Sections 1-3, except Article 6(5), now apply from 2 December 2027 for Annex III systems and 2 August 2028 for Article 6(1) product-linked systems. Other provisions remain on the general date unless separately postponed. The amendment was published on 24 July 2026 and entered into force on 27 July.

Earlier phases introduced prohibitions and AI literacy on 2 February 2025, general-purpose model duties and specified governance and penalty provisions on 2 August 2025, and general application on 2 August 2026. The original 2 August 2027 date for Article 6(1) product-linked high-risk duties was later changed.

Does the Act cover a non-EU provider?

Yes, if the provider places an AI system or general-purpose AI model on the Union market, puts an AI system into service in the Union, or is established outside the Union but the AI system output is used in the Union. The answer should record the market, customer, output-use location, and operator role.

How do provider and deployer roles differ?

A provider develops an AI system or GPAI model, or has one developed, and places it on the market or puts the AI system into service under its own name or trademark. A deployer is the organisation using an AI system under its authority. The same organisation may hold different roles for different systems or lifecycle steps.

Which dates should we track?

Use separate calendar entries: 2 February 2025 for the original bans and literacy duty; 2 August 2025 for general-purpose model duties and specified governance and penalties; 2 August 2026 for general application, most transparency duties and model enforcement powers; 2 December 2026 for the new content-generation ban and the marking transition for qualifying older systems; 2 August 2027 for models marketed before 2 August 2025; 2 December 2027 for Annex III Chapter III Sections 1-3, except Article 6(5); and 2 August 2028 for the equivalent Article 6(1) product-linked provisions. The amendment entered into force on 27 July 2026.

  • Article 2 covers providers placing AI systems or GPAI models on the Union market, EU deployers, certain third-country providers and deployers where the output is used in the Union, importers, distributors, product manufacturers, authorised representatives, and affected persons in the Union.
  • A provider develops, or has developed, an AI system or GPAI model and places it on the market or puts an AI system into service under its own name or trademark.
  • A deployer uses an AI system under its authority, except for personal non-professional use.
  • The AI Act excludes areas outside Union law and several military, defence, national security, and specified international cooperation uses.
Question 2

Is the use prohibited or high-risk?

The Commission explains four system risk levels: unacceptable, high, limited or transparency, and minimal or no risk. These labels help explain the Act; the specific articles decide the duties. Transparency duties can overlap high-risk duties. General-purpose AI models have separate rules.

Screen the bans in Article 5 first. They cover specified harmful manipulation and exploitation, certain social scoring and criminal-risk prediction based solely on profiling or personality traits, untargeted scraping for facial-recognition databases, and workplace or education emotion recognition except for medical or safety reasons.

Article 5 also prohibits certain sensitive biometric categorisation and generally prohibits law-enforcement real-time remote biometric identification in publicly accessible spaces, with narrow exceptions. The 2026 amendment adds a ban from 2 December 2026 for specified non-consensual intimate material and child sexual abuse material.

Then check the two high-risk routes: covered products or safety components under Article 6(1), and listed uses under Article 6(2) and Annex III. Article 6(3) provides a limited exception for some Annex III systems.

Is every AI system high-risk?

No. Some uses are prohibited, some systems are high-risk, and some have specific transparency duties. Many systems fall within the Commission's minimal-or-no-risk label. This does not remove all applicable duties or other laws. General-purpose AI models have a separate framework, and transparency duties can overlap high-risk duties.

When does the product-safety route apply?

Article 6(1) applies when the AI system is intended as a safety component of a product, or is itself a product, covered by listed Union harmonisation legislation and that product or system must undergo third-party conformity assessment before market placement or putting into service.

Can an Annex III system qualify as non-high-risk?

Sometimes. Article 6(3) requires no significant risk of harm to health, safety, or fundamental rights, including through the absence of material influence on decision-making. The system must also fit at least one listed condition: a narrow procedural task; improvement of a completed human activity; detection of decision patterns or deviations without replacing or influencing a completed human assessment without proper human review; or a preparatory task for an Annex III assessment. An Annex III system that profiles natural persons is always high-risk. The provider must document the assessment before market placement or first service and register the system under Article 49(2).

  • For Article 5, document the exact intended purpose, users, affected persons, data source, deployment context, and whether any exception or Member State authorisation route is being relied on.
  • For Article 6(1), check whether the AI system is a safety component of a product, or is itself a product, covered by listed Union harmonisation legislation and subject to third-party conformity assessment.
  • For Annex III, check biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration and border control, and justice or democratic-process use cases.
  • If a provider concludes an Annex III system is not high-risk under Article 6(3), it must document that assessment before market placement or putting into service and register the system under Article 49(2).
Question 3

What must high-risk providers and users do?

Providers must meet the high-risk system requirements and prepare the pre-release evidence: quality management, technical documentation, controlled logs, conformity assessment, EU declaration, CE marking and applicable registration. They also handle corrective action and cooperation with authorities.

Deployers use the system under their authority. Follow instructions, assign competent human oversight, monitor operation and control relevant input data where it is under your control.

Keep deployer-controlled logs for an appropriate period of at least six months unless another applicable law provides otherwise. Inform affected workers before workplace use. Inform people when an Annex III high-risk system makes or assists decisions about them.

What records does a high-risk provider need?

A provider should have the Article 16 compliance package: quality management, technical documentation, logs where under its control, conformity assessment records, EU declaration of conformity, CE marking evidence, Article 49 registration, corrective-action records, and materials needed to demonstrate conformity to competent authorities.

Who needs a fundamental rights impact assessment?

A FRIA is required before first deployment of covered Article 6(2) high-risk systems by bodies governed by public law or private entities providing public services, and by deployers of Annex III point 5(b) creditworthiness or credit-scoring systems and point 5(c) life and health insurance risk-assessment and pricing systems. Annex III point 2 critical-infrastructure systems are excluded. The deployer can cross-reference or include relevant parts of an existing data protection impact assessment (DPIA) where it already meets overlapping obligations, and must assess the remaining fundamental-rights issues.

Who registers systems in the EU database?

For covered Annex III high-risk systems, the provider or authorised representative registers itself and the system before market placement or putting into service. Public authorities, Union institutions, bodies, offices, agencies, and persons acting on their behalf must register themselves, select the system, and register their use before putting the system into service or using it.

What belongs in a serious-incident file?

For high-risk systems, keep the event chronology, affected system, harm, affected persons or groups, provider and deployer notifications, authority notifications, corrective measures, logs, and post-market monitoring evidence. For GPAI models with systemic risk, the Commission template asks for start and end dates, harm, chain of events, model involved, evidence of involvement, response, recommendations, root cause analysis, and post-market monitoring patterns.

What does the EN 18286:2026 citation change?

Decision (EU) 2026/2274 cited EN 18286:2026 in the Official Journal on 14 October 2026. Conformity with its relevant clauses supports presumption of conformity only for covered requirements, subject to Annex ZA conditions. It does not establish whole-Act compliance, remove required conformity assessment or change application dates. Use the harmonised standards and quality-management guide to check the coverage and connect provider procedures to system evidence.

  • A fundamental rights impact assessment (FRIA) is required before first deployment of covered Article 6(2) high-risk systems by bodies governed by public law or private entities providing public services, and by deployers using Annex III point 5(b) creditworthiness or credit-scoring systems or point 5(c) life and health insurance risk-assessment and pricing systems. Article 27 excludes Annex III point 2 critical-infrastructure systems.
  • The FRIA must describe the deployer process, period and frequency of use, affected groups, likely fundamental-rights risks, human oversight measures, and risk-response measures including internal governance and complaint mechanisms.
  • Article 49 registration applies before placing on the market or putting into service many Annex III high-risk systems, with separate provider, authorised-representative, and public-authority deployer registration routes.
  • For high-risk AI systems, providers must report serious incidents under Article 73 to the competent market surveillance authority, or to the AI Office where Article 75(1a) applies; deployers that identify a serious incident must inform the provider first and then the importer or distributor and the relevant market surveillance authority or AI Office, as applicable.
Question 4

What about general-purpose models and AI disclosures?

General-purpose AI (GPAI) model providers follow Chapter V. Article 53 requires model documentation, information for downstream system builders, a copyright policy and a public training-content summary using the AI Office template. Article 55 adds evaluation, risk mitigation, incident and security duties for models with systemic risk.

Article 50 assigns specific disclosure duties. Providers address direct AI interactions and technical marking of generated content. Deployers address biometric or emotion-recognition notices, deepfake disclosure and certain AI-generated public-interest text. Check each paragraph's exceptions and timing.

What must general-purpose model providers do?

Article 53 requires GPAI model providers to maintain model technical documentation, provide downstream information needed by AI-system providers, maintain a policy for EU copyright compliance, publish a summary of training content using the AI Office template, and cooperate with the Commission and competent authorities.

What extra duties apply to models with systemic risk?

Article 55 adds model evaluation with state-of-the-art protocols and adversarial testing, assessment and mitigation of systemic risks at Union level, serious-incident tracking and reporting without undue delay, and adequate cybersecurity protection for the model and physical infrastructure.

When must users be told they are interacting with AI?

Article 50 requires providers of AI systems intended to interact directly with natural persons to design and develop the system so people are informed they are interacting with an AI system, unless that is obvious to a reasonably well-informed, observant, and circumspect person in the circumstances and context of use.

When must generated content be marked or disclosed?

Article 50 requires provider-side machine-readable marking for synthetic audio, image, video, or text outputs where the rule applies. Deployers must disclose deepfakes, and must disclose AI-generated or manipulated public-interest text unless a listed exception applies, such as human review or editorial control with editorial responsibility.

  • From 2 August 2025, obligations for GPAI providers enter into application for models placed on the market after that date; providers of GPAI models placed on the market before 2 August 2025 have until 2 August 2027 to comply.
  • Third-country providers of GPAI models must appoint an EU authorised representative before placing the model on the Union market, unless the open-source exception applies and the model does not present systemic risk.
  • Providers of AI systems that interact directly with natural persons must inform them they are interacting with an AI system unless that is obvious in context.
  • Providers of systems generating synthetic audio, image, video, or text must ensure outputs are marked in machine-readable format and detectable as artificially generated or manipulated, subject to the Article 50 exceptions. Regulation (EU) 2026/1744 gives systems placed on the market before 2 August 2026 until 2 December 2026 to comply with this provider-side duty.
Question 5

What rights and support does the Act provide?

Providers and deployers must support staff AI literacy. People have complaint rights and, for specified decisions, explanation rights. The Act also provides regulatory sandboxes and proportionate support for smaller organisations.

Check the conditions for each provision. Explanation rights apply to specified decisions, sandbox testing has defined limits, and smaller-company support depends on the particular article.

What does AI literacy require?

From 27 July 2026, amended Article 4 requires providers and deployers to take measures that support the development of AI literacy for staff and other people operating or using AI systems on their behalf. The measures must reflect technical knowledge, experience, education, training, use context, and affected people, but the organisation does not have to guarantee a specific literacy level for every individual. Evidence can include the audience assessment, role-based material, completion records, operating guidance, and updates when the system or use changes.

Can someone complain about an infringement?

Yes. Article 85 allows a natural or legal person that has grounds to consider there has been an infringement to submit a complaint to the relevant market surveillance authority. The appropriate authority depends on the Member State, system, sector, and enforcement allocation. This route sits alongside other administrative or judicial remedies available under Union or national law.

Can people request an explanation for every AI decision?

Article 86 covers specified significant decisions, rather than every AI output. The decision must be taken by a deployer using output from an Annex III high-risk system, excluding point 2 critical infrastructure. It must produce legal effects or similarly significantly affect the person in a way they consider adverse to their health, safety or fundamental rights. The person can seek a clear, meaningful explanation of the system's role and the decision's main elements. Other EU-law rights and lawful exceptions or restrictions can affect applicability.

Does a regulatory sandbox waive the duties?

No. A sandbox provides a controlled framework and authority supervision for eligible development, training, testing, or validation. Participants still need safeguards, documentation, and a route to full compliance before placing a covered system on the market, putting it into service, or using it outside the permitted sandbox conditions. Article 5 prohibited practices are not converted into acceptable uses by sandbox participation.

Are startups and smaller companies exempt?

No. The Act includes proportionate support, reduced conformity-assessment fees, priority sandbox access in specified circumstances, simplified technical-documentation or quality-management measures where provided, and penalty rules that account for smaller undertakings. The substantive duty still applies unless the relevant article creates a specific exclusion or simplification.

Which authority handles questions or enforcement?

Member States designate national competent authorities and a single point of contact, while market surveillance and notifying authorities have different functions. The European AI Office supports implementation and has central responsibilities for general-purpose AI models. Sector rules can affect the competent route, so record the Member State, system category, actor, and issue before naming an authority.

  • Amended AI literacy duty: from 27 July 2026, providers and deployers must take measures to support the development of AI literacy for staff and other people operating or using AI systems on their behalf. They do not have to guarantee a specific level for every individual.
  • Complaint: a natural or legal person with grounds to consider that the Regulation has been infringed can complain to the relevant market surveillance authority under Article 85.
  • Explanation: Article 86 applies to specified decisions based on output from Annex III high-risk systems when the decision produces legal effects or similarly significantly affects the person in a way they consider to have an adverse impact on their health, safety, or fundamental rights.
  • Sandbox: Article 57 supports supervised development, training, testing, and validation; participation does not remove the need to comply before market placement or use.
  • Smaller-company support: small and medium-sized enterprises (SMEs), including startups, may use simplified documentation or quality-management routes where the relevant provision allows. Penalty treatment can also be proportionate. Check the specific conditions.
Question 6

What evidence should support a decision?

Keep enough evidence for another person to repeat the decision. Identify the system or model, intended purpose, role, EU market or output-use connection, applicable rule and source.

Supplier claims, model cards and policy summaries can support the facts. Map those facts to the relevant legal provisions: scope, roles, bans, high-risk classification, model duties, transparency, impact assessment, registration and incidents.

What should an assessment avoid?

Avoid unsupported deadlines, penalty figures, thresholds, exemptions, or authority routes. If the source does not support the answer, mark the issue as unresolved instead of filling the gap from memory or vendor marketing.

What is the minimum useful decision record?

Keep the AI system or model name, intended purpose, operator role, risk classification, source citation, decision owner, affected launch or deployment, required artifact, approval history, and reassessment trigger for product, model, supplier, market, or legal changes.

  • Scope record: market, establishment, output-use location, operator role, affected persons, exclusions considered, and source citation.
  • Classification record: Article 5 screen, Article 6(1) product-safety route, Annex III use case, Article 6(3) derogation assessment if used, and profiling check.
  • High-risk record: provider obligations, deployer obligations, conformity assessment route, technical documentation, logs, human oversight, instructions for use, registration, FRIA, and incident escalation.
  • GPAI record: model provider identity, open-source status, systemic-risk assessment, technical documentation, downstream information, copyright policy, training-content public summary, authorised representative where needed, and AI Office submission route.
  • Transparency record: interaction notice, machine-readable synthetic-content marking, biometric or emotion-recognition notice, deepfake disclosure, public-interest text disclosure, accessibility, timing, and exception analysis.
Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Primary legal text supporting scope, roles, AI literacy, prohibited practices, high-risk classification, high-risk obligations, transparency, GPAI duties, serious incidents, registration, and staged application.
  • Supports Article 2 scope, Article 3 operator definitions, Article 4 AI literacy, and Article 113 staged application dates.
  • Supports Article 6 high-risk classification rules, Annex III high-risk areas, and Article 6(3) non-high-risk documentation.
Show 3 more
  • Supports Article 16 provider obligations, Article 26 deployer obligations, Article 72 post-market monitoring, and Article 73 serious-incident reporting for high-risk AI systems.
  • Supports Article 50 transparency obligations and Articles 53 to 55 GPAI provider obligations.
  • Primary source for the scope, role, prohibited-practice, high-risk, transparency, GPAI, governance, registration, and incident records referenced in the evidence checklist.
"laying down harmonised rules on artificial intelligence"
More quoted passages
"It shall apply from 2 August 2026."
"AI systems referred to in Annex III shall be considered to be high-risk."
"Providers of high-risk AI systems shall:"
"Providers of general-purpose AI models shall:"
"harmonised rules for the placing on the market"
eur-lex.europa.eu5 citations
Referenced sections
  • Binding amendment used for revised application dates, the new prohibited-practice category, amended AI literacy wording, the Article 50 transition, and the Article 75(1a) serious-incident reporting route.
  • Supports publication and entry into force, revised high-risk dates, the new prohibited-practice application date, and the provider-side Article 50 transition.
  • Supports the new Article 5 category for specified non-consensual intimate material and child sexual abuse material and its 2 December 2026 application date.
Show 2 more
  • Supports the 2 December 2026 transition for provider-side synthetic-output marking and detection.
  • Supports amended Article 4: measures must support AI literacy development, with no duty to guarantee a specific level for each individual.
digital-strategy.ec.europa.eu3 citations
Referenced sections
  • Commission FAQ used for practical explanations of high-risk systems, conformity assessment, EU database registration, transparency, and GPAI obligations.
  • Commission FAQ explains high-risk examples, conformity assessment, quality management, and EU database registration at a practical level.
  • Commission FAQ used to cross-check practical explanations of high-risk compliance steps, transparency obligations, and GPAI duties.
"Navigating the AI Act"
More quoted passages
"providers of high-risk AI systems have to register the system"
"What are the obligations"
ai-act-service-desk.ec.europa.eu2 citations
Referenced sections
  • Article-specific source for fundamental rights impact assessment triggers, contents, first-use rule, updates, and authority notification.
  • Supports who must perform a fundamental rights impact assessment, when it is required, and the assessment contents.
"Fundamental rights impact assessment for high-risk AI systems"
More quoted passages
"Prior to deploying a high-risk AI system"
ai-act-service-desk.ec.europa.eu2 citations
Referenced sections
  • Official article page for AI literacy factors; read alongside the amended Article 4 duty to support literacy development.
  • Article-specific source for the role, knowledge, experience, context, and affected-person factors used to plan sufficient AI literacy.
"AI literacy"
More quoted passages
"taking into account their technical knowledge, experience, education and training"
ai-act-service-desk.ec.europa.eu2 citations
Referenced sections
  • Article-specific source for EU database registration duties for providers, authorised representatives, and certain deployers.
  • Supports EU database registration duties for providers, authorised representatives, and certain deployers of high-risk AI systems.
"Registration"
More quoted passages
"Before placing on the market or putting into service"
ai-act-service-desk.ec.europa.eu2 citations
Referenced sections
  • Article-specific source for prohibited-practice screening, including manipulation, exploitation, social scoring, biometric categorisation, emotion recognition, and remote biometric identification.
  • Supports the prohibited-practice screening questions, including manipulative practices, social scoring, biometric categories, and real-time remote biometric identification conditions.
"Prohibited AI practices"
More quoted passages
"The following AI practices shall be prohibited:"
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission overview used for public explanation of risk categories, high-risk compliance measures, GPAI rules, and transparency rules.
  • Provides Commission overview of the AI Act risk categories, high-risk compliance steps, GPAI rules, and transparency rules.
"The AI Act is the first-ever comprehensive legal framework on AI worldwide."
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission page supporting Article 50 implementation context for marking and labelling AI-generated or manipulated content.
  • Supports the Article 50 implementation context for marking, labelling, deepfake disclosures, and transparency codes of practice.
"marking and labelling of AI-generated content"
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission source for the AI Office's implementation and GPAI responsibilities within the wider governance structure.
  • Commission source explaining the AI Office's implementation, enforcement, international, and general-purpose AI responsibilities.
"European AI Office"
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission guidance on the scope and staged enforcement expectations for providers of general-purpose AI models.
  • Supports the GPAI obligation scope, enforcement staging, Code of Practice context, and EU SEND submission route.
"general-purpose AI models"
More quoted passages
"These obligations enter into application on 2 August 2025."
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission page supporting serious-incident reporting content for general-purpose AI models with systemic risk.
  • Supports the serious-incident report contents for GPAI models with systemic risk and the Article 55 reporting context.
"serious incidents involving general-purpose AI models"
More quoted passages
"serious incidents involving general-purpose AI models with systemic risk"
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission template page supporting the GPAI training-content public summary requirement under Article 53(1)(d).
  • Supports the public summary of training content requirement and the Commission template baseline for GPAI providers.
"Public Summary of Training Content"
More quoted passages
"common minimal baseline"
eur-lex.europa.eu
Referenced sections
  • Primary legal source for AI literacy, regulatory sandboxes and real-world testing, national authorities, complaints, and the defined right to an explanation of individual decision-making.
"adverse impact on their health, safety or fundamental rights"
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Check Article 50 chatbot notices, synthetic-output marking, biometric notices, deepfake disclosures and public-interest text exceptions.

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