{"meta":{"dataset_id":"praxikon:sys:registry:dataset:ai-act-implementation-graph","dataset_version":"2.2.0","schema_version":"1.5.0","lang":"en","effective_at":"2026-08-08T00:00:00.000Z","known_at":"2026-09-06T00:00:00.000Z","count":1,"filters":{"id":"praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route","type":"obligation","role":null,"duty_holder":null,"topic":null},"identifiers":{"canonical_namespace":"praxikon","canonical_form":"praxikon:<jurisdiction>:<regulation>:<type>:<slug>","legacy_namespace":"raip","legacy_resolution":"permanent","resolved":{"id":"praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route","role":null,"duty_holder":null}}},"data":[{"id":"praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route","legacy_id":"raip:obligation:article-6-1bis-1quater-route","type":"obligation","slug":"article-6-1bis-1quater-route","version":"1.0.0","effective_at":"2026-07-27T00:00:00.000Z","known_at":"2026-08-14T00:00:00.000Z","valid_until":null,"payload_hash_sha256":"b1a3c8f90e9a6725cbe17956c5c8b7e1eef30c09b708afd4f0758b446f53b35f","label":"Article 6(1a) to (1c): the tightened classification route","summary":"The Digital Omnibus inserts three paragraphs into Article 6 that draw the notion of safety component more tightly: which AI systems do not qualify as safety components, which still do despite that exclusion because failure would endanger health and safety, and which mandatory third-party conformity assessment does not count. Paragraph 1a is written for the purposes of the Regulation as a whole and therefore bears on both the Annex I route and Annex III, point 2.","topics":["conformity","high-risk"],"actor_ids":["praxikon:eu:ai-act:actor:provider"],"duty_holder_ids":["praxikon:eu:ai-act:actor:provider"],"affected_actor_ids":[],"oversight_actor_ids":[],"evidence_owner_ids":["praxikon:eu:ai-act:actor:provider"],"duty_holder_uncertainty_status":null,"interpretation_status":"preliminary","interpretation_note":"The legal text below is settled; our reading of the route is not, which is why the whole object stands as preliminary. Three things. First, the sharpest textual tension, and it is not where you would look for it. In the adopted text of paragraph 1a the qualifier \"non-safety related aspects of\" governs the entire list, including user assistance and performance optimisation. In recital 7 that qualifier attaches to quality control alone: it says this does not in particular include AI systems intended to solely fulfil functions related to user assistance, performance optimisation, service efficiency, automation, convenience, or non-safety related aspects for quality control operations. We read the operative text, so with the qualifier across the whole list. A defensible alternative is the recital-conform, narrower reading in which only quality control is limited to non-safety related aspects and the rest is excluded unconditionally. Second, what paragraph 1a looks at. The text says \"are used\", while recital 7 is explicit: the safety function should be an intended purpose of the system, determined by the provider, and the mere fact that an AI system is integrated into or operates within a regulated product does not, in itself, mean that it fulfils a safety function. That second sentence and the amended definition in Article 3, point (14), make this question less open than it seems; we read it as the intended purpose. The alternative reading remains that actual use decides, so that a provider loses the exclusion as soon as a customer deploys the system differently. Third, from when. The amended definition sits in Chapter I and operates now, and the paragraphs have been binding law since 27 July 2026. They steer a live classification only once the route itself applies: 2 December 2027 for Annex III, point 2, and 2 August 2028 for the Annex I route. A defensible alternative reading is that the paragraphs, sitting in Chapter III, Section 1, do not operate at all before the later date. One point of candour: the published definition object on Article 3, point (14), still carries the unamended text and the reading that a component need not have an identifiable safety function. That is exactly what is qualified here, and while both objects stand side by side the text in this object governs.","obligation_ids":[],"change_ids":[],"action_ids":["praxikon:eu:ai-act:action:assess-safety-component-role"],"evidence_ids":["praxikon:eu:ai-act:evidence:safety-component-assessment-record"],"control_ids":["praxikon:eu:ai-act:control:safety-component-reassessment-trigger"],"template_ids":["praxikon:eu:ai-act:template:article-6-1bis-1quater-legal-text"],"conditions":[{"id":"article-6-1-annex-i-route","operator":"any","description":"Applies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity."},{"id":"article-6-1-section-a-only","operator":"all","description":"For the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply."}],"exceptions":[{"id":"article-6-1bis-non-safety-functions","operator":"not","description":"Paragraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components."},{"id":"article-6-1quater-non-safety-conformity-assessment","operator":"not","description":"Paragraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b)."}],"statements":[{"kind":"official_fact","text":"Article 6(1) provides: irrespective of whether an AI system is placed on the market or put into service independently of the products referred to in points (a) and (b), that AI system shall be considered to be high-risk where both of the following conditions are fulfilled: (a) the AI system is intended to be used as a safety component of a product, or the AI system is itself a product, covered by the Union harmonisation legislation listed in Annex I; (b) the product whose safety component pursuant to point (a) is the AI system, or the AI system itself as a product, is required to undergo a third-party conformity assessment, with a view to the placing on the market or the putting into service of that product pursuant to the Union harmonisation legislation listed in Annex I.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6(1)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"Regulation (EU) 2026/1744 inserts three paragraphs into Article 6. Paragraph 1a: \"For the purposes of this Regulation, including paragraph 1 of this Article, AI systems that are solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control shall not qualify as safety components.\" Paragraph 1b: \"Notwithstanding paragraph 1a, AI systems the failure or malfunctioning of which would endanger health and safety shall qualify as safety components.\" Paragraph 1c: \"A product that is required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, shall not be considered as fulfilling the condition in paragraph 1, point (b).\"","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Inserted Article 6(1a)-(1c)","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"The same Regulation amends the definition in Article 3, point (14). As amended it reads: \"safety component\" means a component of a product or of an AI system which fulfils a safety function for that product or AI system, or the failure or malfunctioning of which endangers the health and safety of persons or property; for the purposes of this definition, a component fulfils a safety function where its intended purpose is to prevent or mitigate risks to the health and safety of persons or property. Article 3 sits in Chapter I, which under Article 113, third paragraph, point (a), has applied since 2 February 2025. This amended definition therefore operates from the entry into force of the amending Regulation on 27 July 2026 and not only from some later application date.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 3(14)","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"The amended Article 113, third paragraph, point (c), provides that Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5), shall apply from: (i) 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III; and (ii) 2 August 2028 as regards AI systems classified as high-risk pursuant to Article 6(1) and Annex I. The added point (d) provides that Articles 102 to 110 shall apply from 27 July 2026. Annex III, point 2, uses the notion of safety component for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity; that route falls under the 2 December 2027 date.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 113 application dates","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"The same Regulation moves machinery out of Chapter III. In Annex I, Section A, point 1 (the reference to Directive 2006/42/EC) is deleted and Section B gains point 21: Regulation (EU) 2023/1230 on machinery. The amended Article 2(2) reads that for AI systems classified as high-risk in accordance with Article 6(1) related to products covered by the Union harmonisation legislation listed in Section B of Annex I, only Article 6(1), Article 60a and Articles 102 to 112 shall apply. The amended Article 43(3) adds that the classification of a product as a high-risk AI system in accordance with Article 6(1) does not affect the choice of the conformity assessment procedure provided to manufacturers of products covered by Annex I, Section A, and that those manufacturers are not required to choose a procedure involving third-party conformity assessment only because the product includes a high-risk AI system as a safety component, if the Section A legislation does not require it. The new Article 2(13) provides that specific requirements or obligations under Articles 9 to 15 and 17 to 25 may be limited where Section A legislation provides an equivalent or higher level of protection, and obliges the Commission to adopt delegated acts on this by 2 August 2027.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 2(2), Article 43(3) and Annex I","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"editorial_interpretation","text":"What changes in practice is what the discussion is about. Until now it was about whether your product falls under Annex I and whether a third party is involved. Those two questions remain, but a third one belongs in front of them: what function does your AI component actually perform. A recommendation model that optimises when a machine is serviced, or a model that improves throughput on a line, sits in the list in paragraph 1a, and such functions often ended up classified as safety components simply because they ran inside a regulated product. Be careful with quality control as an example: paragraph 1a names only the non-safety related aspects of it, and in many regulated products a vision model that flags deviations is safety QC. Paragraph 1b draws the line: as soon as failure or malfunctioning would endanger health and safety, the exclusion does not count. The question therefore moves from your product file to your failure analysis, and at most providers that analysis is recorded nowhere. Paragraph 1c is narrower: anyone who needed a third party only because of radio spectrum or electromagnetic interference does not meet paragraph 1, point (b), by that route. That paragraph too requires a weighing, because it works only if the third party is mandatory solely on account of those other risks; where your product falls under several Annex I acts, a second act may still satisfy the condition on health and safety grounds. Two things finally that move the stakes. Machinery no longer runs through this route: Regulation (EU) 2023/1230 now sits in Annex I, Section B, and for those products the amended Article 2(2) means Chapter III does not apply at all. And for Section A products the same Regulation pushes the other way: the amended Article 43(3) says expressly that classification under Article 6(1) does not affect the choice of conformity assessment procedure and pushes nobody towards a notified body who was not already headed there. So build your failure analysis as your own file, not as something you will have to put in front of a notified body anyway.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Inserted Article 6(1a)-(1c)","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 2(2), Article 43(3) and Annex I","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"editorial"}},{"kind":"recommended_action","text":"This is our recommendation and not a legal duty: paragraphs 1a to 1c are delimiting rules and impose no obligation on anyone. First establish whether your product falls under Annex I, Section A or Section B; for Section B, which now includes machinery, Chapter III stops here. For Section A, record per AI component which function it performs, whether that is a safety function within the meaning of the amended Article 3, point (14), and what happens on failure or malfunctioning. Note which of the three paragraphs you apply and why. Use that file to support your own classification, not because a notified body asks for it: the amended Article 43(3) points the other way. Keep two dates apart: 2 December 2027 for the route via Annex III, point 2, and 2 August 2028 for the route via Annex I.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Inserted Article 6(1a)-(1c)","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 2(2), Article 43(3) and Annex I","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"editorial"}}],"legal_status":"in_force","deadline_at":"2027-12-02T00:00:00.000Z","timing_basis":null,"high_risk_regime_from":null,"links":[{"relation":"public_page","href":"https://www.praxikon.com/en/verplichtingen/article-6-1bis-1quater-route","label":"Open the human explanation"},{"relation":"official_source","href":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","label":"Inserted paragraphs on EUR-Lex"},{"relation":"related","href":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","label":"Article 6 on EUR-Lex"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"},"source_review":{"level":"source_verified","last_checked_at":"2026-08-14T00:00:00.000Z","next_review_due_at":"2027-02-10T00:00:00.000Z","date_basis":"first_publication"}}],"included":{"sources":[{"id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","title":{"nl":"EU AI-verordening 2024/1689","en":"EU Artificial Intelligence Act 2024/1689"},"publisher":{"nl":"Europees Parlement en Raad","en":"European Parliament and Council"},"canonical_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj","source_version":"original-oj-2024-07-12","verified_at":"2026-08-08T00:00:00.000Z","fingerprint_basis":"canonical_url|source_version|verified_at","source_record_hash_sha256":"bf0fca3e1fb47ce58924f6e736d572bb5db3812c3276c0b2891fbf328c42a5c6","review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"},"legacy_id":"raip:source:reg-eu-2024-1689"},{"id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","title":{"nl":"Digital Omnibus over AI 2026/1744","en":"Digital Omnibus on AI 2026/1744"},"publisher":{"nl":"Europees Parlement en Raad","en":"European Parliament and Council"},"canonical_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj","source_version":"official-journal-2026-07-24","verified_at":"2026-08-08T00:00:00.000Z","fingerprint_basis":"canonical_url|source_version|verified_at","source_record_hash_sha256":"17f108dc4eb93b8ff3abf091ab8a6a6e3095ae112229f27ca9a59ded886c7864","review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"},"legacy_id":"raip:source:reg-eu-2026-1744"}]},"links":{"self":"https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-6-1bis-1quater-route&lang=en","alternate":"https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-6-1bis-1quater-route&lang=en&format=jsonld","licence":"https://www.praxikon.com/nl/legal/terms"}}