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AI Act

Find out which AI Act duties apply to you as a provider or user of AI, and when.

AI Act

What clients ask us

Does the AI Act apply to us, and as provider or deployer?

It applies if you develop AI systems, put them on the EU market under your name, or use them in a professional context in the EU. A provider develops or brands a system; a deployer uses one under its own authority. Many companies are both, for example when they build an AI feature into their own product. Roles drive the obligations, so record the role per system.

Is our AI system high-risk?

A system is high-risk if it is a safety component of a product covered by certain EU product legislation, or if its purpose falls in an Annex III area such as recruitment, education, credit scoring, essential services, law enforcement or migration. Intended purpose decides, not the technology. There are narrow exceptions for systems that do not materially influence decisions. Document your reasoning per system. Pitch classifies systems with the supporting articles and evidence.

What do we need to do now, and what can wait?

Already applying: the ban on prohibited practices and AI literacy since 2 February 2025, and the transparency duties of Article 50 since 2 August 2026. High-risk obligations were postponed to 2 December 2027 (Annex III systems) and 2 August 2028 (product-related AI), but conformity work takes months. Dates have moved before, so confirm them on EUR-Lex. Start with an inventory and classification of your systems.

What is the AI literacy obligation, and do we have to train staff?

Article 4 applies to providers and deployers of any AI system, not only high-risk ones, and has applied since 2 February 2025. You must take measures to promote an adequate level of AI literacy among staff and others using AI on your behalf, taking account of their role and context. There is no prescribed course, so a documented, proportionate programme is the practical answer.

Do we have to tell people they are talking to an AI chatbot or seeing AI-generated content?

Generally yes. Since 2 August 2026, Article 50 requires that people are told when they interact with an AI system, unless that is obvious. Providers of generative systems must mark synthetic output in a machine-readable way, with a grace period for systems already on the market, and deployers must disclose deepfakes and certain AI-generated text on matters of public interest. Check your chatbot and marketing workflows.

We only use third-party tools like ChatGPT or Copilot. Does the Act still concern us?

Yes, as a deployer. You must ensure AI literacy, respect transparency duties, and for high-risk uses follow the provider's instructions, keep human oversight and logs. Staff may also use tools you do not know about, so an inventory and a usage policy matter. Check the supplier contract too: who bears liability, where data goes, and whether your inputs train the model.

Can we use AI in recruitment and HR?

Yes, but AI used to recruit, screen, evaluate, promote or monitor workers is high-risk under Annex III, and emotion recognition at work is prohibited. Deployers must use it per instructions, assign trained human oversight, inform affected workers and keep logs. The GDPR applies in parallel, including limits on solely automated decisions, and a DPIA is often needed. Involve works council or staff representatives where the rules require it.

How do the AI Act and the GDPR fit together?

They apply side by side. The AI Act regulates the system and its risk class, the GDPR regulates the personal data it uses, so one AI project can need both a conformity file and a DPIA. Lawful basis, data minimisation, transparency and automated decision rights remain with the GDPR. Aligning registers, assessments and documentation avoids doing the work twice. Pitch links both in one set of registers.

What are the penalties for getting it wrong?

Fines scale with the breach: up to EUR 35 million or 7% of worldwide annual turnover for prohibited practices, and lower tiers for other obligations, with caps designed to be proportionate for SMEs. Enforcement sits mainly with national market surveillance authorities, so check which authority in each country where you operate applies to your sector. Beyond fines, customers and investors increasingly ask for proof of readiness in questionnaires and contracts.

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