The European Commission published the Draft Commission guidelines on the classification of high-risk AI systems on 19 May 2026 and opened a targeted consultation the same day. The consultation closed on 23 July 2026, having been extended from an original closing date of 23 June 2026. The guidelines remain in draft, and the Commission has stated that final guidelines will be adopted by the end of 2026.
The draft is issued under Article 6(5) of Regulation (EU) 2024/1689, which directs the Commission to provide guidelines on the practical implementation of the classification rules for high-risk AI systems. Section III of the draft addresses AI systems that are products, or safety components of products, covered by the Union harmonisation legislation listed in Annex I. Section IV addresses the standalone use cases listed in Annex III.
Providers deciding whether a recruitment screening tool, a creditworthiness model or an AI safety component in a regulated product falls inside Annex III are the intended audience. Classification decides whether the obligations in Chapter III of the Regulation attach, covering risk management, data governance, technical documentation, record keeping, human oversight and conformity assessment. Vendors selling into EU hiring and workforce management are reading the Annex III use cases closely for that reason.
Guidelines of this kind do not bind national market surveillance authorities or the Court of Justice, and the text may change before adoption. The consultation window has closed, so providers that did not file a response will work from the final version when the Commission publishes it.
Licentium advises AI providers and deployers on classification, documentation and conformity duties under Regulation (EU) 2024/1689. Work we undertake includes Annex III scoping opinions, high-risk classification memoranda, technical documentation review, and deployer obligation mapping for workforce and financial services use cases.