Tool 04 · EU AI Act
Does this apply to you?
What this is. A pre-check along Regulation (EU) 2024/1689, known as the EU AI Act. Ten questions, giving a classification: which role you hold, which risk class the system falls into, which obligations apply from when. Not an audit report. Classification under Annex III turns on features a questionnaire cannot reliably capture. The deadlines were amended in summer 2026 (the so-called Digital Omnibus): high-risk obligations apply later than originally planned. The new position is reflected below.
The system is placed on the market or used in the EU — or its output is used here.Art. 2 AI Act. The provider’s seat is irrelevant.
It is an AI system within the meaning of the Act.Machine-based, with some degree of autonomy, producing outputs such as predictions, recommendations or decisions from inputs. A pure rule or formula is not. This refers to the term as defined in the Act; in the discipline itself, rule-based systems are AI too.
We develop the system or place it on the market under our own name or trade mark.Art. 3(3). Rebranding or substantially modifying a third party’s high-risk system makes you the provider (Art. 25).
We use a system under our own authority in a professional capacity.Art. 3(4) — deployer obligations catch pure users too.
The system scores people socially, infers emotions at work or in education, infers protected characteristics from biometric data, or deliberately exploits vulnerabilities.Art. 5 — prohibited practices. In force since 02.02.2025.
It contributes to decisions on employment, education, creditworthiness, insurance, critical infrastructure, law enforcement or migration.Annex III — the fields in which a system is regularly high-risk.
It is a safety component of a product that already requires conformity assessment (machinery, medical device, vehicle).Art. 6(1) in conjunction with Annex I.
People interact with the system directly, or it generates image, audio, video or text for the public.Art. 50 — transparency obligations. Even where risk is otherwise minimal.
We develop or modify a general-purpose AI model ourselves.Chapter V. Buying in a model and using it does not make you a GPAI provider.
Our staff working with the system are trained for it.Art. 4 — AI literacy. In force since 02.02.2025 and routinely overlooked.
10 of 10 questions still open — no classification
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