Who does it apply to?

Providers and deployers of high-risk AI in employment, education, credit, essential services, law enforcement, migration and justice

What evidence is expected?

Risk classification record, impact assessment, vendor documentation, oversight design.

Deadline tracker · EU

High-risk obligations for stand-alone systems (Annex III)

Q: When does "High-risk obligations for stand-alone systems (Annex III)" apply?

2 December 2027 (Deferred). Risk management, data governance, technical documentation, logging, human oversight, conformity assessment and registration. Deferred from 2 August 2026 by the Digital Omnibus.

Risk management, data governance, technical documentation, logging, human oversight, conformity assessment and registration. Deferred from 2 August 2026 by the Digital Omnibus.

Date: 2 December 2027 (in 436 days)
Status: Deferred
Law: EU AI Act as amended by Reg. 2026/1744
Jurisdiction: EU
Applies to: Providers and deployers of high-risk AI in employment, education, credit, essential services, law enforcement, migration and justice
Evidence expected: Risk classification record, impact assessment, vendor documentation, oversight design.
Source: Gibson Dunn, Omnibus agreement
Last reviewed: 2026-09-21

What to do

Check whether it applies to you with the readiness scan.
Record the obligation against each affected system in your AI inventory.
The Compliance Kit holds the document that produces the evidence for this row.

Related obligations

AI literacy duty, Article 4 2025-02-02
General-purpose AI model obligations 2025-08-02
Transparency obligations, Article 50 2026-08-02
Machine-readable marking of generative AI output 2026-12-02

Cite this

Dutybound, "High-risk obligations for stand-alone systems (Annex III)", AI regulation deadline tracker, reviewed 2026-09-21, https://getdutybound.com/deadlines/eu-annex-iii/. Primary source: https://www.gibsondunn.com/eu-ai-act-omnibus-agreement-postponed-high-risk-deadlines-and-other-key-changes/.