Article 6: Classification of High-Risk AI Systems
Article 6 sets out two routes into the high-risk category: Article 6(1) for AI embedded as a safety component in products already regulated under EU product-safety law (Annex I), and Article 6(2) for standalone AI used in the use cases listed in Annex III. A provider can avoid high-risk status for an Annex III use case under the Article 6(3) carve-out if the system poses no significant risk, but must document that assessment and register it.
- 02 Dec 2027 Annex III standalone high-risk obligations apply (Art. 6(2)) — shifted from the original 2 August 2026 by Regulation (EU) 2026/1744
- 02 Aug 2028 Annex I product-safety route obligations apply (Art. 6(1)) — shifted from the original 2 August 2027
- Determine at design stage whether the system falls under the Annex I product-safety route (Art. 6(1)) or the Annex III use-case route (Art. 6(2)).
- If relying on the Article 6(3) carve-out for an Annex III use case, document the reasoning and register the self-assessment in the EU database before placing the system on the market.
- Note that the carve-out never applies if the system profiles natural persons — such systems remain high-risk automatically.
- Re-assess classification whenever the system's intended purpose changes, since this can flip a non-high-risk system into a high-risk one.
- Track that Annex I and Annex III systems now follow different applicability dates.
- Documented Article 6(3) self-assessment, where relied on
- EU database registration record
Article 6(1) and 6(2) are often treated as sharing one deadline; the Digital Omnibus actually gave them different dates — 2 December 2027 for Annex III, 2 August 2028 for the Annex I product route.
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 Art. 6
- Loading from the public feed…
- Regulation (EU) 2024/1689 on EUR-Lex
- Look for Article 6
- Deadline changes and the acts behind them
Get told when Art. 6 moves.
Deadlines under this regulation have already shifted once in 2026. A signed webhook, a REST API and an MCP server carry the same record this page is built from, so your systems learn about the next change without anyone re-reading the text. Free during the beta.
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.