The AI Act applies to every company that uses AI professionally and to providers that place AI systems on the market or build them into products. Complass guides you from the AI register through classification to the obligations of your role.
The AI Act is Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence, last amended by Regulation (EU) 2026/1744. It prohibits certain AI practices, sets requirements for high-risk AI systems, lays down transparency obligations and requires providers and deployers to take measures for the AI literacy of their staff.
Content as of:
Does it apply to me?
The Regulation applies across the EU to providers, deployers, importers, distributors and product manufacturers of AI systems. Anyone using AI professionally is a deployer and must at least support the AI literacy of their staff and rule out prohibited practices. Further obligations depend on the risk of the intended purpose, for example for AI in recruitment or as a safety component of a product.
Since Regulation (EU) 2026/1744, the obligations for high-risk AI systems apply from 2 December 2027 under Annex III and from 2 August 2028 under Annex I. For AI safety components of machinery, the requirements will in future come via the Machinery Regulation.
This overview does not replace legal advice. The legal or normative text is authoritative; in Complass you check applicability with guidance based on the references.
Legal basis
Art. 2 KI-VOArticle 2 AI ActScope1. This Regulation applies to: - (a) providers placing on the market or putting into service AI systems or placing on the market general-purpose AI models in the Union, irrespective of whether those providers are established or located within the Union or in a third country; - (b) deployers of AI systems that have their place of establishment or are located within the Union; - (c) providers and deployers of AI …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗Scope
Art. 3 KI-VOArticle 3 AI ActDefinitionsFor the purposes of this Regulation, the following definitions apply: (1) ‘AI system’ means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗Definitions
Art. 4 KI-VOArticle 4 AI ActAI literacy1. Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗AI literacy
Art. 5 KI-VOArticle 5 AI ActProhibited AI practices1. The following AI practices shall be prohibited: - (a) the placing on the market, the putting into service or the use of an AI system that deploys subliminal techniques beyond a person’s consciousness or purposefully manipulative or deceptive techniques, with the objective, or the effect of materially distorting the behaviour of a person or a group of persons by appreciably impairing their ability to make an …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗Prohibited practices
Art. 6 KI-VOArticle 6 AI ActClassification rules for high-risk AI systems1. Irrespective of whether an AI system is placed on the market or put into service independently of the products referred to in points (a) and (b), that AI system shall be considered to be high-risk where both of the following conditions are fulfilled: - (a) the AI system is intended to be used as a safety component of a product, or the AI system is itself a product, covered by the Union harmonisation legislation …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗Classification as a high-risk AI system
Art. 26 KI-VOArticle 26 AI ActObligations of deployers of high-risk AI systems1. Deployers of high-risk AI systems shall take appropriate technical and organisational measures to ensure they use such systems in accordance with the instructions for use accompanying the systems, pursuant to paragraphs 3 and 6. 2. Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support. 3. The obligations set out in …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗Obligations of deployers of high-risk AI systems
Art. 27 KI-VOArticle 27 AI ActFundamental rights impact assessment for high-risk AI systems1. Prior to deploying a high-risk AI system referred to in Article 6(2), with the exception of high-risk AI systems intended to be used in the area listed in point 2 of Annex III, deployers that are bodies governed by public law, or are private entities providing public services, and deployers of high-risk AI systems referred to in points 5 (b) and (c) of Annex III, shall perform an assessment of the impact on …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗Fundamental rights impact assessment for high-risk AI systems
Art. 50 KI-VOArticle 50 AI ActTransparency obligations for providers and deployers of certain AI systems1. Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use. This …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗Transparency obligations
Key dates
Entry into force of the Regulation · Art. 113(1)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
Chapters I and II apply: AI literacy (Art. 4) and prohibited practices (Art. 5) · Art. 113(3)(a)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
Obligations for providers of general-purpose AI models, governance, penalties, notified bodies · Art. 113(3)(b)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
Regulation (EU) 2026/1744 in force; Art. 102 to 110 apply · Art. 113(3)(d)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
General application, in particular transparency obligations under Art. 50 · Art. 113(2)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
New prohibitions under Art. 5(1), first subparagraph, points (ba) and (bb) and Art. 5(1a) and (1b); marking under Art. 50(2) for systems placed on the market before 02.08.2026 · Art. 113(3)(a), Art. 111(4)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
End of the transitional period for general-purpose AI models placed on the market before 02.08.2025 · Art. 111(3)Article 111 AI ActAI systems already placed on the market or put into service and general-purpose AI models already placed on the marked1. Without prejudice to the application of Article 5 as referred to in Article 113(3), point (a), AI systems which are components of the large-scale IT systems established by the legal acts listed in Annex X that have been placed on the market or put into service before 2 August 2027 shall be brought into compliance with this Regulation by 31 December 2030. The requirements laid down in this Regulation shall be …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
High-risk AI systems under Annex III: requirements and obligations of providers and deployers apply · Art. 113(3)(c)(i)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
High-risk AI systems under Art. 6(1) and Annex I: requirements and obligations apply · Art. 113(3)(c)(ii)Article 113 AI ActEntry into force and applicationThis Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 August 2026. However: - (a) Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026; - (b) Chapter III Section 4, …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
Deadline for high-risk AI systems intended to be used by public authorities and already placed on the market before · Art. 111(2)Article 111 AI ActAI systems already placed on the market or put into service and general-purpose AI models already placed on the marked1. Without prejudice to the application of Article 5 as referred to in Article 113(3), point (a), AI systems which are components of the large-scale IT systems established by the legal acts listed in Annex X that have been placed on the market or put into service before 2 August 2027 shall be brought into compliance with this Regulation by 31 December 2030. The requirements laid down in this Regulation shall be …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 27.07.2026Open original (EUR-Lex – consolidated version of 27.07.2026) ↗
Key dates according to the consolidated version of 27.07.2026. Delegated acts, guidelines and harmonised standards of the Commission supplement the Regulation step by step.
Nine phases from roles and governance through the AI register and classification to deployer and provider obligations, transparency and regular review.
Catalogue of obligations by role
The main obligations for deployers, providers, importers, distributors and product manufacturers with original wording, status and evidence.
Templates
AI policy, AI register, classification record, AI literacy plan, deployer checklist, fundamental rights impact assessment, transparency notices and, for providers, risk management plan and technical documentation according to Annex IV.
Training on AI literacy
Learning blocks for all employees and for those responsible for AI governance, with assignment, progress and participation certificate as evidence for Art. 4.
Deployer obligations and fundamental rights impact assessment
For high-risk AI systems that you operate, Complass tracks the obligations under Art. 26 paragraph by paragraph with status, owner, measure, evidence and resubmission date. For the fundamental rights impact assessment under Art. 27, Complass gives a hint based on your classification as to whether it may be required; you take the decision and record the reasons. You capture the six items under Art. 27(1) in a guided way, with the date of the notification to the market surveillance authority.
The phases in the module
Project start, AI governance and roles
AI inventory: record AI systems and AI models
Classification: prohibited, high-risk, subject to transparency or minimal risk
AI literacy (Art. 4)
Deployer obligations for high-risk AI systems
Provider obligations for high-risk AI systems (short form)
Transparency obligations (Art. 50)
General-purpose AI models (GPAI)
Operation, monitoring and supervision
Catalogue: Catalogue of obligations by role and article
Good to know: You can also meet the obligations without Complass. Complass supports you with implementation and evidence but does not replace legal advice. Legal information
Frequently asked questions
We only use a chat assistant. Does the AI Act affect us?+
Yes, as a deployer: you must take measures for the AI literacy of users and rule out prohibited practices. Further obligations only arise for high-risk purposes or transparency cases.
We build machines with AI features. Which rules apply?+
AI for quality control or performance optimisation is not considered a safety component. For AI safety components of machinery only a few articles of the AI Act apply; the requirements come via the Machinery Regulation. Complass links the AI Act, Machinery Regulation and CRA projects for this.
Do we have to carry out a fundamental rights impact assessment?+
Only in certain cases. Art. 27(1) obliges deployers that are bodies governed by public law or private entities providing public services, as well as deployers of high-risk AI systems under Annex III point 5(b) and (c) (creditworthiness, risk assessment and pricing in life and health insurance), before first use. The obligation does not apply to high-risk AI systems in the area of critical infrastructure (Annex III point 2). Complass gives a hint based on your classification; you take the decision.
Does Complass replace a legal review?+
No. Complass structures classification, obligations and evidence based on the legal text; the legal assessment of the individual case remains with you.
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