Artifact GuideEU

EU AI Act High-Risk AI Use Cases by Industry

Classify industry AI systems under the EU AI Act by separating Article 6 product-safety routes from Annex III use cases.

This page helps spot likely high-risk systems, document carveouts, assign provider and deployer work, and avoid treating every AI feature as the same risk class.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 31, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 31, 2026
Overview

The EU AI Act has two routes to a . Article 6(1) covers AI used as a safety component of, or itself constituting, a product covered by Annex I Union harmonisation legislation when that product route requires third-party conformity assessment. Article 6(2) covers the Annex III use cases, subject to the Article 6(3) carveout; an Annex III system that profiles natural persons remains high-risk. Regulation (EU) 2026/1744 entered into force on 27 July 2026 and applies Chapter III Sections 1-3 from 2 December 2027 for Annex III systems and 2 August 2028 for Article 6(1) systems. Classification still matters before those dates because it determines the applicable route and preparation work.

Section 1

Start with the two Article 6 routes

Do not classify by industry label alone. A hospital, bank, manufacturer, school, recruiter, utility, or public authority can have low-risk, limited-risk, prohibited, and high-risk AI in the same portfolio.

First test Article 6(1): is the AI system a safety component of a covered product, or the product itself, under Annex I product legislation, and is third-party conformity assessment required under that sector law? Then test Article 6(2): is the intended purpose one of the Annex III use cases?

  • Article 6(1) route: product-safety sectors such as machinery, toys, radio equipment, medical devices, in vitro diagnostic medical devices, lifts, pressure equipment, personal protective equipment, vehicles, rail, aviation, marine equipment, and related Annex I legislation.
  • Article 6(1) safety-component check: an AI system used solely for non-safety user assistance, performance optimisation, service efficiency, automation, convenience, or quality control is not a safety component. A system whose failure or malfunction would endanger health and safety is a safety component. A product does not satisfy Article 6(1)(b) when third-party assessment is required only for risks unrelated to health and safety, such as radio-spectrum distribution or electromagnetic interference that does not affect health and safety.
  • Article 6(2) route: Annex III areas covering biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration and border control, justice, and democratic processes.
  • Article 6(3) carveout: some Annex III systems are not high-risk if they do not pose a significant risk of harm, including where they only perform a narrow procedural task, improve a completed human activity, detect decision-pattern deviations without replacing or influencing human assessment, or perform a preparatory task.
  • Profiling limit: an Annex III system that performs profiling of natural persons is always treated as high-risk under Article 6(3).
  • Evidence to keep: intended purpose, user context, affected natural persons, product-safety route if any, Annex III category if any, carveout reasoning if used, the role responsible for provider or deployer duties, and the obligation-specific application date.
Section 2

Industry examples that often trigger Annex III

Annex III is best read as a use-case list, not a complete industry list. The same industry can appear under multiple Annex III headings depending on what the AI system is intended to do.

Use the examples below as classification prompts. They do not make every AI system in that industry high-risk; the intended purpose and actual deployment context still control the answer.

  • Biometrics and security: remote biometric identification, sensitive biometric categorisation, and emotion recognition can fall under Annex III when permitted by relevant Union or national law; biometric verification used only to confirm a claimed identity is excluded from the remote biometric identification entry.
  • Energy, transport, water, gas, heating, and digital infrastructure: AI used as a safety component in managing critical digital infrastructure, road traffic, or supply of water, gas, heating, or electricity is an Annex III critical-infrastructure use case.
  • Education and vocational training: admissions ranking, assignment to institutions, learning-outcome evaluation, education-level assessment, and exam-proctoring systems for prohibited behaviour are Annex III use cases.
  • HR, staffing, and platform work: targeted job ads, CV screening, candidate evaluation, promotion or termination decisions, task allocation based on behaviour or personal traits, and worker performance monitoring map to the employment Annex III category.
  • Banking, insurance, healthcare access, and public services: creditworthiness or credit scoring, life and health insurance risk assessment and pricing, public-benefit eligibility decisions including healthcare services, and emergency-call triage or dispatch prioritisation are Annex III use cases.
  • Public sector, justice, and civic processes: law-enforcement risk tools, evidence reliability tools, migration and asylum risk or application-assistance tools, judicial legal-research tools used for concrete cases, and AI intended to influence elections or voting behaviour can fall under Annex III.
Section 3

Product-safety sectors: when Annex I matters

Annex I matters where the AI system is tied to product safety. The classification question is not simply whether a manufacturer uses AI; it is whether the AI is the product, or a safety component of a covered product, and whether that sector route requires third-party conformity assessment.

This route is especially relevant for AI in regulated physical products or safety-critical software embedded in them. Regulation (EU) 2026/1744 makes the exact Annex I section decisive. Section A systems generally combine the AI Act with the sector conformity route, subject to future delegated acts that may limit overlapping requirements where sector law provides equivalent protection. For Section B systems, only the amended Article 2(2) AI Act provisions apply directly unless the relevant requirements have been integrated into sector law. Machinery moves into Section B and receives AI-related health and safety requirements through amendments to the Machinery Regulation.

  • Medical and in vitro diagnostic devices: AI diagnostic, triage, imaging, or monitoring systems may need an Article 6(1) check where they are the device or a safety component of a device subject to the relevant sector conformity route.
  • Industrial equipment and machinery: AI controlling protective stops, robot motion, safety interlocks, or equipment behaviour should be checked against the machinery and related Annex I routes before relying only on Annex III.
  • Mobility and transport: driver-assistance, vehicle-safety, rail, aviation, unmanned-aircraft, and marine-equipment AI can require product-safety analysis under the sector legislation listed in Annex I.
  • Consumer and workplace products: toys, lifts, pressure equipment, gas appliances, personal protective equipment, radio equipment, and equipment for explosive atmospheres need an Article 6(1) screen where AI affects safety performance.
Section 4

Exclusions and carveouts to record before assigning obligations

A useful high-risk register should show why a system is high-risk and why nearby systems are not. This avoids over-scoping low-risk tools and under-scoping systems that make or influence decisions about people.

The AI Act also contains scope exclusions that should be separated from Article 6(3). An Article 2 exclusion means the Regulation does not apply to that activity or actor in the described circumstances; an Article 6(3) carveout is a classification result for an Annex III system that would otherwise be high-risk.

  • Article 2 scope exclusions include areas outside Union law, military, defence or national security purposes, certain scientific research and development uses, pre-market research, testing and development activity, purely personal non-professional deployer use, and free and open-source AI systems unless they are placed on the market or put into service as high-risk systems or systems under Article 5 or Article 50.
  • Article 6(3) carveouts must be documented before placing the Annex III system on the market or putting it into service, and providers using the carveout are subject to Article 49(2) registration.
  • Examples that may need carveout analysis include a HR tool that only formats a completed human interview note, a school dashboard that only prepares administrative lists, or a credit model monitor that detects deviations without influencing a previously completed human assessment.
  • Do not use a carveout for systems that profile natural persons in an Annex III use case, or for systems that materially influence decision-making outcomes affecting health, safety, or fundamental rights.
Section 5

Trace each industry case from provider to affected person

Use one record per deployed decision or safety function. The same vendor model can produce different legal results when a hospital, employer, bank, school, emergency service, or manufacturer gives it a different intended purpose.

The examples below are routing examples, not automatic classifications. Confirm the legal use case, the actor controlling the intended purpose, any product-law route, the people affected, and whether an Article 6(3) carveout or another exception can apply.

  • Medical imaging triage: identify whether the AI is a medical device or safety component under Article 6(1), who places it on the market as provider or product manufacturer, how the hospital deploys it, which patients are affected, and which sector conformity route controls. A separate scheduling assistant in the same hospital is not high-risk merely because healthcare uses it.
  • Creditworthiness: an AI system evaluating a natural person's creditworthiness or establishing a credit score can fall within Annex III. Record the model provider, the bank or lender's deployer role, the borrower population, input-data controls, human review, affected-person information, and any FRIA duty. Fraud detection is excluded from that Annex III entry but still needs a separate AI Act screen.
  • Recruitment screening: CV ranking or candidate evaluation can fall within Annex III. Record who set the intended purpose, whether the employer or vendor became the provider, the job applicants affected, worker-representative information where relevant, oversight, logs, and any change from administrative support to recommendation or ranking.
  • Admissions and exam proctoring: admissions ranking, learning-outcome evaluation, education-level assessment, and prohibited-behaviour monitoring during tests can fall within Annex III. Keep the education provider's deployer controls, the student group, accessibility and vulnerable-person risks, human review, notices, and the reason any narrow procedural carveout is claimed.
  • Emergency dispatch: AI used to evaluate and classify emergency calls or prioritise dispatch can fall within Annex III. Record the public or private deployer, provider documentation, critical service context, affected callers, fallback process, response-time and error testing, FRIA position, and incident escalation.
  • Machine safety control: AI controlling a protective stop, robot motion, or safety interlock requires an Article 6(1) product-law analysis. Record the product manufacturer, upstream AI provider, operator or deployer, exposed workers, Annex I instrument, third-party assessment trigger, and the amended Section B machinery treatment.
Section 6

Provider and deployer boundaries for industry teams

High-risk classification is only the start. The work changes depending on whether the organisation is the provider placing the system on the market or putting it into service, a deployer using it under its authority, or another operator in the value chain.

Industry teams should avoid pushing all work to either legal or the vendor. For Annex III and applicable Section A routes, the provider usually owns conformity, technical documentation, quality management, logs under its control, registration, CE marking where required, and corrective actions. The deployer owns use according to instructions, human oversight, monitoring, input data under its control, workplace and affected-person notices where applicable, and some registration or impact-assessment duties. For Section B and machinery routes, map the record to the amended sector law instead of assuming the full standalone AI Act package applies directly.

Are all AI tools in banking, HR, healthcare, or education automatically high-risk under the EU AI Act?

No. The AI Act classifies by intended purpose and route, not by industry name alone. A creditworthiness tool, recruitment-screening system, medical-device AI, or admissions-ranking system may be high-risk, while a general drafting assistant or internal analytics tool in the same organisation may fall outside Article 6 high-risk classification unless another AI Act rule applies.

When can an Annex III EU AI Act system be treated as not high-risk?

Article 6(3) allows a non-high-risk result for some Annex III systems that do not pose a significant risk of harm, such as systems limited to narrow procedural, preparatory, improvement, or decision-pattern detection tasks. The provider must document that assessment before market placement or putting into service, register under Article 49(2), and cannot use this route for Annex III systems that perform profiling of natural persons.

  • Provider evidence: intended purpose, Article 6 route, Annex I or Annex III mapping, requirements testing, technical documentation, quality management system, conformity assessment route, declaration of conformity, registration, post-market monitoring, and corrective-action process.
  • Deployer evidence: instructions for use, local use case, human oversight assignment, input-data checks where the deployer controls inputs, monitoring records, incident escalation, worker notices for workplace use, affected-person notices for Annex III decision support, and FRIA where Article 27 applies.
  • Procurement evidence: contract clauses and supplier records should show the provider/deployer split, access to instructions for use, logs or monitoring data where available, escalation contacts, change-notification triggers, and whether the system is registered when required.
  • Change triggers: reassess classification after substantial modification, new intended purpose, new sector deployment, new affected-person category, new product-safety use, or a switch from internal support to decision assistance about natural persons.
Recommended next step

Turn industry use cases into a sourced Article 6 register

Sorena can help turn product, vendor, and deployment facts into a cited high-risk classification register with Article 6 routes, Annex III categories, carveout records, and provider/deployer evidence requests.

Primary sources

References and citations

ai-act-service-desk.ec.europa.eu
Referenced sections
  • Official Service Desk article page for the Article 6 classification rule and the non-high-risk assessment record.
"Classification rules for high-risk AI systems"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission overview summarising high-risk areas such as critical infrastructure, education, employment, essential services, biometrics, law enforcement, migration, asylum, and border control.
"AI use cases that can pose serious risks"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission FAQ summarising provider and deployer obligations for high-risk AI systems in practical terms.
"What are obligations of deployers of high-risk AI systems?"
eur-lex.europa.eu
Referenced sections
  • Primary legal text for Articles 16, 26, and 27 provider, deployer, and fundamental-rights-impact-assessment duties.
"Obligations of providers and deployers of high-risk AI systems"
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