Annex III: List of High-Risk Use Cases
Annex III lists the use-case categories that make a standalone AI system high-risk under Article 6(2): biometrics, critical infrastructure, education and vocational training, employment and worker management, access to essential services, law enforcement, migration and border control, and administration of justice and democratic processes. Falling into a category does not automatically mean the system is high-risk in every case, because of the Article 6(3) carve-out for systems posing no significant risk — except where the system profiles natural persons.
- 02 Dec 2027 Annex III obligations apply, shifted from 2 August 2026 by Regulation (EU) 2026/1744
- Check whether the system's intended use falls into one of the eight Annex III categories.
- If it does, apply the Article 6(2) high-risk obligation set unless the Article 6(3) carve-out applies and is documented.
- Remember the carve-out never applies if the system profiles natural persons.
- Watch for Commission amendments to Annex III via delegated acts, since the category list is not permanently fixed.
- Use-case classification assessment against the eight Annex III categories
Annex III is often treated as a fixed, exhaustive list that automatically means high-risk status; it is subject to Commission amendment, and the Article 6(3) self-assessment carve-out means category membership alone doesn't always equal high-risk status in practice.
Unsettled: Whether the Digital Omnibus altered the substance of any individual Annex III category, beyond timing and the Annex I/III boundary mechanism, was not fully verified against the EUR-Lex primary text in the underlying research.
What regulators published on Annex III
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- Regulation (EU) 2024/1689 on EUR-Lex
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- Deadline changes and the acts behind them
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Get free accessInformational content only. Not legal advice and not a substitute for qualified counsel. Dates reflect Regulation (EU) 2026/1744 as of 04 Aug 2026.