AI Act: obligations for high-risk systems under Annex III

Recruitment, employee assessment, biometrics, access to services: obligations from 2 December 2027.

AWhat changed

Following the amendment by Regulation (EU) 2026/1744, the obligations for stand-alone high-risk AI systems listed in Annex III (e.g. employment, education, biometrics, access to essential services) apply from 2 December 2027.

BWhen

2 December 2027. AI in regulated products under Annex I: 2 August 2028.

CWho it affects

Companies that develop or use AI for recruiting, assessing or monitoring employees.
Banks, insurers and others that use AI in decisions about access to services.

DWhat to do

Map the AI systems in your company and classify them by risk.
For high-risk systems, plan risk management, documentation, human oversight and record-keeping.

Explanation

The omnibus also extended the relief for SMEs (e.g. simplified technical documentation) to so-called small mid-caps.

Sources

Last checked: 12 October 2026 · How we correct errors