Deadline tracker · EU
High-risk obligations for stand-alone systems (Annex III)
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 423 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
- Calendar
- Add this date (.ics) · Google Calendar · subscribe to all dates
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.
Worked examples
- An AI tool screens and ranks job applications High-risk (Annex III)
- AI writes job ads, or decides who sees them Depends on the use
- AI monitors and scores employees' productivity High-risk (Annex III)
- AI scores consumers' creditworthiness High-risk (Annex III)
- AI prices life or health insurance for individuals High-risk (Annex III)
- AI grades tests or monitors exams in a training company High-risk (Annex III)
Related obligations
- AI literacy duty, Article 4 2025-02-02
- Prohibited AI practices, Article 5 2025-02-02
- General-purpose AI model obligations 2025-08-02
- Transparency obligations, Article 50 2026-08-02
Get an email before each date
One email 30 days and one 7 days before each date in the markets you tick, with who it applies to and what to have ready. Next: Machine-readable marking of generative AI output, 2 Dec 2026.
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/.