EU AI Act Sets August 2, 2026 Compliance Deadline for High-Risk AI Systems Under Annex III

Regulation (EU) 2024/1689 of the European Parliament and of the Council, published in the Official Journal on 12 July 2024 (the EU AI Act), entered into force on 1 August 2024. The Act applies in phases. The obligations specific to high-risk AI systems listed in Annex III become applicable on 2 August 2026, two years after the Act's entry into force, under Article 113(b). Providers and deployers of in-scope high-risk AI systems must be fully compliant with Chapters III and IV of the Act by that date.

Annex III of the EU AI Act lists eight categories of high-risk AI systems subject to the 2 August 2026 deadline. These categories cover AI systems used in: biometric identification and categorisation of natural persons; management and operation of critical infrastructure; education and vocational training; employment, worker management, and access to self-employment; access to and enjoyment of essential private services and public benefits; law enforcement; migration, asylum, and border control management; and administration of justice and democratic processes. Article 6 sets out the conditions under which a system listed in Annex III qualifies as high-risk. Under Article 6(3), Annex III systems that pose only limited risk of harm to health, safety, or fundamental rights are excluded from the high-risk classification following a self-assessment procedure.

By 2 August 2026, providers of Annex III high-risk AI systems must complete a conformity assessment under Article 43, establish a quality management system under Article 17, maintain technical documentation under Article 11, register the system in the EU database established under Article 71, and affix a CE marking where applicable under Article 48. Deployers must conduct a fundamental rights impact assessment under Article 27 before deploying a high-risk AI system in contexts covered by Article 27(1). Providers established outside the EU who place high-risk AI systems on the EU market must appoint an authorised representative in the EU under Article 22. National market surveillance authorities designated under Article 70 will enforce the Act from the same date.

Article 113(a) applies the prohibitions on unacceptable-risk AI systems under Article 5 from 2 February 2025. Article 113(c) extends the deadline for high-risk AI systems embedded in regulated products under Annex I — including medical devices, machinery, and motor vehicles — to 2 August 2027, three years after the Act entered into force. General-purpose AI model obligations under Article 53 apply from 2 August 2025. Providers of high-risk AI systems already placed on the market before 2 August 2026 benefit from a transitional period under Article 111, which permits continued use of existing systems under specified conditions until 2 August 2031 for Annex I products and until 2 August 2029 for Annex III systems, provided no substantial modification is made.

Source: Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 on Artificial Intelligence, OJ L 2024/1689, 12.07.2024, Articles 6, 11, 17, 22, 27, 43, 48, 53, 70, 71, 111, 113, and Annexes I and III. Full text available at eur-lex.europa.eu (CELEX 32024R1689). Confirmed March 12, 2026.

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