High-Risk AI System

A high-risk AI system is an AI system that the EU AI Act regulates particularly strictly: either as a safety component of a regulated product under Annex I, or because it is used in one of the sensitive areas listed in Annex III. These include recruitment, creditworthiness assessment, critical infrastructure, education, law enforcement and the judiciary. For Annex III systems, Article 6(3) also provides an exception where the system poses no significant risk of harm. High-risk systems face stricter obligations than ordinary AI applications: risk management, technical documentation, human oversight and a conformity assessment before they go to market.

In practice

Important right now (as of 14 August 2026): the deadlines for high-risk systems have been postponed. Under Regulation (EU) 2026/1744 ("Digital Omnibus on AI", OJ L, 2026/1744 of 24 July 2026, in force since 27 July 2026), standalone high-risk systems under Annex III now face 2 December 2027 instead of the original 2 August 2026, and high-risk AI embedded in products under Annex I 2 August 2028. For companies this means more time to prepare, but it is no all-clear: anyone planning AI-assisted shortlisting of applicants, for example, should still review classification and documentation duties early, since political deadlines can be adjusted again.

Matching service

Sources

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