Check the product-law route before assigning duties. Annex I Section A products may need both AI Act high-risk controls and sector-law controls. Section B products follow amended Article 2(2): only Article 6(1), Article 60a and Articles 102-112 apply directly. Articles 57-59 apply only where high-risk requirements have been integrated into sector law.
For Section A, an Article 2(13) limitation needs an applicable delegated act; existing sector controls alone do not establish an exemption.
Article 8 is the gateway: high-risk AI systems must comply with the requirements in Section 2, taking account of the system's intended purpose and the state of the art.
For product-regulated systems, the AI Act requirements can be integrated with existing product documentation and testing where the product is also covered by Union harmonisation legislation.
Article 16 then turns those requirements into provider obligations. The provider must meet Section 2 requirements, identify itself on the system or accompanying documentation, and maintain quality management. Keep required documentation and logs under provider control. Complete the assessment, declaration, CE marking and registration where required.
Take corrective action, demonstrate conformity to authorities and meet applicable accessibility requirements.
For systems supplied or first used before their Chapter III application date, amended Article 111(2) applies the high-risk operator rules only if significant design changes occur from that date. Annex X large-scale IT systems follow the separate rule in Article 111(1).
Chapter III Sections 1-3, except Article 6(5), apply from 2 December 2027 for Article 6(2) Annex III systems and 2 August 2028 for Article 6(1) Annex I systems.
This transition rule uses a different test from the Article 43 substantial-modification rule that reopens conformity assessment, so record the first placement or service date, type and model, change description, and legal test instead of treating every software update alike.
Article 111(2) also requires providers and deployers of high-risk systems intended for public-authority use to take the necessary steps to comply by 2 August 2030.
Article 17 governs the provider quality management system alongside the Section 2 system requirements. EN 18286:2026 was cited in the Official Journal on 14 October 2026. Its presumption of conformity is limited to covered requirements and Annex ZA conditions; keep separate evidence for uncovered obligations and for the system requirements in Articles 8-15.