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The EU AI Act: what outside firms must know

What the law is, the four risk levels, who it reaches beyond Europe, the dates that matter and a practical checklist for a mid-size company.

Updated 7 min read

The short answer

The EU AI Act is a European law that sorts AI systems by risk and sets duties for the companies that build or use them. Firms outside Europe are covered when their AI is sold or used in the EU. Duties phase in between 2025 and 2028.

Key points

  • Risk-based law with four levels of risk
  • Covers providers and deployers, including US firms
  • Banned practices have applied since 2 February 2025
  • Transparency duties are scheduled from 2 August 2026
  • Fines can reach 3 percent of worldwide turnover

What the EU AI Act is

  1. 01

    Classify the system

    Decide which risk level it falls into

  2. 02

    Find your role

    Provider or deployer

  3. 03

    Follow the rules

    Duties depend on the class

  4. 04

    Keep records

    Document how the system works

The EU AI Act is the first set of rules on AI adopted by the European Union, agreed in June 2024, according to the European Parliament.

It works by risk. The higher the risk an AI system poses to people, the more duties fall on the company behind it.

Wondering what is the EU AI Act in one line? It is a product-safety style law for AI: classify the system, then follow the rules for that class.

This guide is general information, not legal advice. Ask a qualified lawyer before acting on any rule.

The four risk levels

  • Unacceptable

    Practices that are prohibited

  • High risk

    Strict duties and assessment

  • Limited risk

    Tell people they are dealing with AI

  • Minimal risk

    No extra duties under the Act

The EU AI Act risk categories run from banned uses at the top to systems with no new duties at the bottom.

Unacceptable risk covers practices the law bans outright. The Parliament says the ban started to apply on 2 February 2025.

High-risk systems face the heaviest duties. The Parliament notes they are assessed before reaching the market and throughout their lifecycle.

Limited-risk systems mainly carry transparency duties. Generative tools are not labeled high-risk, but they must meet transparency requirements and EU copyright law.

Does the EU AI Act apply outside Europe?

Likely in scope

  • Sells AI to EU customers
  • AI output is used in the EU
  • Deploys AI for EU users

Check carefully

  • Internal use only in the US
  • No EU customers or users
  • Tools bought off the shelf

Yes, in many cases. The Parliament describes obligations for both providers and users of AI, depending on the risk level.

A US company that sells an AI product to EU customers, or whose AI output is used in the EU, should assume the law is relevant.

A firm that only deploys a tool inside its own US operations, with no EU users, is in a different position. Confirm this with counsel.

  • Provider: builds the system or puts it on the market
  • Deployer: uses a system in its own business
  • Both roles can sit in one company

EU AI Act timeline and effective dates

  1. 01

    Since 2 February 2025

    Prohibited practices apply

  2. 02

    2 August 2026

    Transparency duties scheduled

  3. 03

    Set for 2 December 2027

    Annex III high-risk rules

  4. 04

    By 2 August 2028

    Full roll-out foreseen

The law applies in stages. The European Commission's service desk says the full roll-out of main milestones is foreseen by 2 August 2028.

Its timeline reflects the changes made by the Digital Omnibus on AI.

Prohibitions began on 2 February 2025. Most Article 50 transparency duties remain scheduled for 2 August 2026, according to law firm Jones Walker.

Rules for high-risk systems listed in Annex III are set to apply on 2 December 2027, per the AI Act explorer at artificialintelligenceact.eu.

A common search is when was the EU AI Act passed. The first rules were adopted in June 2024; the dates above are when each part starts to apply.

Jones Walker calls the delay a reprieve rather than a repeal, so planning should continue.

High-risk systems and what they require

Expect to do

  • Assess before market entry
  • Document the system
  • Keep a human in the loop

Do not assume

  • One check is enough
  • Vendors cover your role
  • Deployers have no duties

Some systems count as high-risk under Article 6(2) and Annex III of the Act.

For those systems, the Parliament says assessment happens before market entry and continues over the system's life.

In practice, expect documentation, risk controls and human oversight. A governance policy is the usual starting point.

If a tool screens job candidates or scores customers, check whether it falls into this class before you deploy it.

  • Document how the system was built and tested
  • Keep human oversight in place
  • Monitor performance after launch
  • Record incidents and fixes

Transparency requirements and Article 50

Article 50 sets transparency duties for certain AI systems, such as telling people when they interact with AI.

Jones Walker notes that most of these duties stay scheduled for 2 August 2026 even after the Digital Omnibus delay.

Chatbots, voice agents and generated content are the usual places these duties show up for a business.

Fines and penalties

Fixed cap

  • Up to €15 million
  • Applies to Article 50 violations

Turnover cap

  • 3 percent of worldwide turnover
  • Whichever amount is higher

Jones Walker reports that Article 50 violations fall in a penalty tier of up to €15 million.

For a company, the alternative cap is 3 percent of total worldwide annual turnover, whichever is higher.

Other parts of the Act carry their own penalty tiers, so check the tier that matches the rule at issue.

EU AI Act compliance checklist

  1. 01

    Inventory

    List every AI system

  2. 02

    Classify

    Assign a risk level

  3. 03

    Assign roles

    Provider, deployer or both

  4. 04

    Set policy

    Name an owner and write rules

  5. 05

    Add oversight

    Human review where it matters

A mid-size company can start without a large legal team. These steps work for most firms.

Voluntary frameworks help. NIST describes its AI Risk Management Framework as voluntary guidance for building trustworthiness into AI design and use.

AI governance consulting is one route to this kind of setup, and an AI risk management process keeps it current.

  • List every AI system you build, buy or use
  • Mark which ones touch EU customers or users
  • Assign each a risk level
  • Decide if you are provider, deployer or both
  • Write a short AI policy and name an owner
  • Add human review where decisions affect people
  • Plan transparency notices before August 2026

Our data

What AI answers when buyers ask

We asked ChatGPT, Gemini and Perplexity 10 buyer questions about AI audit and compliance. They named 85 companies, and 69% appeared in only one of the three.

CriterionChatGPTGeminiPerplexity
Companies named413945
Sites cited mostholisticai.com and deloitte.com (5 of 10)xcelacore.com (4 of 10)aicompliancevendors.com (4 of 10)

Nexum measurement, October 22, 2026, via DataForSEO: 10 buyer questions to each AI, US English, 30 answers in total. 14 companies appeared in all three. Google showed an AI Overview for 10 of the 10 questions.

FAQ

EU AI Act questions

  • The Act is a European law that classifies AI systems by risk and sets duties for companies that develop or use them. The heavier the risk to people, the stricter the rules. Some practices are banned and others need transparency.
  • Yes. The European Parliament says the EU adopted the rules in June 2024. They apply in stages, with prohibitions in force since 2 February 2025 and full roll-out of main milestones foreseen by 2 August 2028.
  • The law can reach US companies that sell AI to EU customers or whose AI is used in the EU. Both providers and users have duties. A firm with no EU link should confirm that with counsel.
  • The Digital Omnibus delayed the Annex III high-risk regime to 2 December 2027. Jones Walker notes most Article 50 transparency duties still apply from 2 August 2026, so 2026 remains a real deadline.
  • Duties depend on your role and the system's risk level. Start by listing your AI systems, classifying them and naming an owner. An AI policy is where you write them down.
  • Article 50 sets transparency duties, such as telling people when they deal with an AI system. Violations fall in a tier with fines up to €15 million or 3 percent of worldwide turnover, whichever is higher.
  • Not safely. The delay covers the Annex III high-risk regime, while most transparency duties stay scheduled for 2 August 2026. Jones Walker describes the delay as a reprieve, not a repeal.
  • Start by mapping where AI is used in your business and where the risk sits. This is not legal advice, so involve a lawyer for the final reading.

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