| Prohibited practices | Both | Art. 5 | 2 Feb 2025 | Product and deployment inventory confirming no system falls in the eight prohibited categories; documented screening before any new AI procurement. |
| AI literacy | Both | Art. 4 | 2 Feb 2025 | Training log by role; coverage of contractors and service providers; evidence of periodic refresh as systems change. |
| Risk management system | Provider | Art. 9 | 2 Dec 2027originally 2 Aug 2026 | Lifecycle risk management plan; risk register with likelihood and mitigation per risk; records showing review after any material change. |
| Technical documentation | Provider | Art. 11, Annex IV | 2 Dec 2027originally 2 Aug 2026 | Complete Annex IV package per system; version control; confirmation it was prepared before deployment, not retrospectively. |
| Transparency to deployers | Provider | Art. 13 | 2 Dec 2027originally 2 Aug 2026 | Instructions for use covering each Art. 13(3) element; audit trail showing deployers received and acknowledged them. Generic model cards do not satisfy this. |
| Human oversight by design | Provider | Art. 14 | 2 Dec 2027originally 2 Aug 2026 | Design documentation showing the oversight interface; test results demonstrating it works; confirmation of a halt or override mechanism. |
| Accuracy, robustness, cybersecurity | Provider | Art. 15 | 2 Dec 2027originally 2 Aug 2026 | Accuracy and robustness benchmarks; adversarial or red team results; cybersecurity or penetration testing report; fallback plan; retest records after updates. |
| Conformity assessment and CE marking | Provider | Art. 43, 47 | 2 Dec 2027originally 2 Aug 2026 | Completed conformity assessment file; signed EU Declaration of Conformity; CE marking; notified body certificate where the third-party route applies. |
| Deployer operational duties (seven sub-obligations) | Deployer | Art. 26 | 2 Dec 2027originally 2 Aug 2026 | Deployment policy referencing provider instructions; named human overseer with training and authority; input data checks; incident log; log retention of at least six months; worker notice; EU database registration for public authorities. None delegable by contract. |
| Reclassification as provider | Deployer becomes provider | Art. 25 | 2 Dec 2027originally 2 Aug 2026 | Change management policy that triggers a reclassification check before any significant modification; legal assessment that intended use stays within the original conformity scope. Fine-tuning, retrieval augmentation or rebranding can quietly trigger this. |
| Fundamental rights impact assessment | Deployer (public bodies and specified Annex III uses) | Art. 27 | 2 Dec 2027originally 2 Aug 2026 | Completed FRIA per in-scope deployment; version history; evidence it was done before first deployment. National DPAs have signalled this is the first document they request. |
| Transparency to natural persons | Both | Art. 50 | 2 Aug 2026not deferred | A disclosure notice in every chatbot or agent interface; technical proof that AI generated outputs are watermarked or marked; a deepfake and synthetic media policy. |
| Post-market monitoring | Provider | Art. 72 | 2 Dec 2027originally 2 Aug 2026 | Monitoring plan inside the Annex IV documentation; evidence data is collected on a schedule; records showing findings feed back into risk management. |
| Serious incident reporting | Provider reports; deployer notifies provider | Art. 73 | 2 Dec 2027originally 2 Aug 2026 | Incident policy with an escalation path to the market surveillance authority; incident log assessed against the serious incident definition; notification within 15 days of establishing a causal link. |
| GPAI documentation and copyright | GPAI provider | Art. 53 | 2 Aug 2025 | Annex XI technical documentation; Annex XII downstream package; copyright policy honouring the Directive (EU) 2019/790 opt-out; published training data summary; Code of Practice sign-on. |
| GPAI systemic risk duties | GPAI provider above 10^25 FLOPs | Art. 55 | 2 Aug 2025 | Model evaluation with red team records; systemic risk assessment and mitigation plan; serious incident notifications to the AI Office; cybersecurity assessment for the model and its infrastructure. |
| Product liability (strict, no fault) | Manufacturers, importers, modifying deployers | Dir. 2024/2853 | 9 Dec 2026 | Product safety documentation for every AI product; evidence security updates are planned and delivered; a retention policy keeping technical records for the duration of potential claims. |