{"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-8-compliance-with-requirements","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-8-compliance-with-requirements","role":null,"duty_holder":null}}},"data":[{"id":"praxikon:eu:ai-act:obligation:article-8-compliance-with-requirements","legacy_id":"raip:obligation:article-8-compliance-with-requirements","type":"obligation","slug":"article-8-compliance-with-requirements","version":"1.0.0","effective_at":"2026-07-27T00:00:00.000Z","known_at":"2026-09-06T00:00:00.000Z","valid_until":null,"payload_hash_sha256":"4f3c944bd22b7f1e7152db7acbc5b5ff00963c180aee232371af34402e112e6f","label":"Article 8: compliance with the requirements for high-risk AI systems","summary":"High-risk AI systems comply with the requirements of Chapter III, Section 2, and that is assessed taking into account the intended purpose and the generally acknowledged state of the art on AI and AI-related technologies, with the risk management system of Article 9 as the instrument. Where the system sits in a product also covered by the Union harmonisation legislation of Section A of Annex I, the provider is responsible for full compliance with all applicable requirements of that legislation, and may integrate the testing and reporting processes and the information and documentation on the product into the documentation and procedures that already exist there.","topics":["conformity","high-risk-requirements"],"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":"What the provision asks of a provider is settled; when it asks it has been derived here. Article 8 sits in Chapter III, Section 2, and names no date of its own. The timeline canon dates the high-risk requirements per route and not per chapter: 2 December 2027 for the systems that are high-risk through Annex III, and 2 August 2028 for those that are high-risk through Annex I. Those two dates do not fit in a field that carries one. `deadline_at` therefore carries 2 December 2027, the earlier of the two and the same date already carried by the objects for Articles 9 to 15. A defensible alternative reading is that a chapeau provision should carry no date of its own and that the dating belongs with the seven requirements it sits above; on that reading this field reads as the earliest of the two routes and not as the date of Article 8. On either reading: for a system inside a regulated product under Annex I, 2 December 2027 is too early and 2 August 2028 is the date that counts. What also remains open is the content of the second measure in paragraph 1. The generally acknowledged state of the art is not a term the Regulation defines and not a synonym for a harmonised standard; anyone who equates it with the standard of Article 40 closes an open measure. On Regulation (EU) 2026/1744. That text was retrieved after all on 6 September 2026 from the Publications Office Cellar service and is archived in data/ai-act/review/sources/reg-eu-2026-1744-nl.txt and -en.txt. The amending regulation carries forty-three amendment points in its Article 1; which of those are reflected in the local legal texts is recorded per point in data/ai-act/review/consolidation-manifest.json. Where a point touches this Article, that is stated below with the statement concerned.","obligation_ids":[],"change_ids":[],"action_ids":["praxikon:eu:ai-act:action:article-8-state-of-the-art-baseline"],"evidence_ids":["praxikon:eu:ai-act:evidence:article-8-state-of-the-art-justification"],"control_ids":["praxikon:eu:ai-act:control:article-8-integrated-documentation-review"],"template_ids":["praxikon:eu:ai-act:template:article-8-legal-text"],"conditions":[{"id":"article-8-scope","operator":"all","description":"Applies to every AI system that qualifies as high-risk under Article 6, along both routes: the system that falls under the Union harmonisation legislation of Annex I as a safety component of a product or as a product in its own right, and the system that falls within one of the areas of Annex III. For the Annex I route there is a limit that this Article does not state itself: Article 2(2), as replaced by Article 1, point (2)(a), of Regulation (EU) 2026/1744, makes only Article 6(1), Article 60a and Articles 102 to 112 applicable to systems related to products covered by Section B of Annex I. Article 8 is not in that list, so for Section B products, machinery among them since 27 July 2026, this provision does not bear. In addition, Article 2(13), inserted by Article 1, point (3), can limit the application of the requirements in Articles 9 to 15 and 17 to 25 for Section A products, but only once the delegated act it prescribes exists. Article 8 sets no additional threshold of its own: what is high-risk is the subject of Article 6 and not of this provision."},{"id":"article-8-two-measures","operator":"all","description":"Compliance is not assessed in the abstract but against two measures at once: the intended purpose of the system, and the generally acknowledged state of the art on AI and AI-related technologies. The second measure lies outside the Regulation and has no fixed content, so what suffices changes without the text changing."},{"id":"article-8-annex-i-product","operator":"any","description":"Paragraph 2 only comes into play where a product contains an AI system to which both the requirements of this Regulation and those of the Union harmonisation legislation listed in Section A of Annex I apply. For a system that is high-risk through Annex III alone, paragraph 2 has no bearing."}],"exceptions":[{"id":"article-8-integration-is-a-choice","operator":"not","description":"The integration in paragraph 2 is a choice and not a duty: providers shall have a choice of integrating, as appropriate, the necessary testing and reporting processes, information and documentation they provide with regard to their product into documentation and procedures that already exist. Anyone who does not integrate breaches nothing. What the provision does not permit is doing less: the responsibility for full compliance with all applicable requirements under the sectoral harmonisation legislation stands undiminished."}],"statements":[{"kind":"official_fact","text":"Paragraph 1 provides that high-risk AI systems shall comply with the requirements laid down in this Section, taking into account their intended purpose as well as the generally acknowledged state of the art on AI and AI-related technologies. The risk management system referred to in Article 9 shall be taken into account when ensuring compliance with those requirements. Paragraph 2 provides that, where a product contains an AI system, to which the requirements of this Regulation as well as requirements of the Union harmonisation legislation listed in Section A of Annex I apply, providers shall be responsible for ensuring that their product is fully compliant with all applicable requirements under applicable Union harmonisation legislation. In ensuring the compliance of high-risk AI systems referred to in paragraph 1 with the requirements set out in this Section, and in order to ensure consistency, avoid duplication and minimise additional burdens, providers shall have a choice of integrating, as appropriate, the necessary testing and reporting processes, information and documentation they provide with regard to their product into documentation and procedures that already exist and are required under the Union harmonisation legislation listed in Section A of Annex I.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 8(1)-(2)","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":"editorial_interpretation","text":"Read Article 8 not as an eighth requirement alongside the seven of Articles 9 to 15, but as the provision that says how those seven are to be read. It does two things none of the seven does itself. The first is that it brings in a measure from outside the Regulation. Article 8 is the only article in Section 2 that names the generally acknowledged state of the art, and that means the bar moves. A file that sufficed at the first conformity assessment does not necessarily still suffice some years later, without a single word of the Regulation changing: what was the state of the art then is no longer the state of the art later. The Regulation provides no re-certification rhythm for this beyond the substantial modification of Article 43(4), so anyone who does not set a rhythm of their own has none. Note also what the measure is not. The state of the art is not a synonym for a harmonised standard: Article 40 gives a presumption of conformity to whoever applies such a standard, but Article 8 sets an open measure alongside it that does not stop applying once the standard has been ticked off. The second is that paragraph 1 designates the risk management system of Article 9 as the instrument through which compliance with the other requirements is assessed. Article 9 is therefore not one requirement beside the other six but the file in which you show that you have met the other six at the right level. An organisation that keeps its risk analysis as a separate document beside the technical documentation misses exactly that connection.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6(1); Article 9(1) and (2); Article 16, point (a); Article 40(1); Article 43(3) and (4); Annex I, Section A","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":"editorial"}},{"kind":"editorial_interpretation","text":"Paragraph 2 is the anti-duplication provision, and in practice it is rarely used. It concerns the product that contains an AI system and falls both under this Regulation and under the Union harmonisation legislation of Section A of Annex I: that is precisely the route of Article 6(1). Two different things are stated. The first is an allocation: the provider is responsible for his product being fully compliant with everything the sectoral legislation requires. It does not say that the AI Act replaces or lightens the sectoral requirements, nor that the sectoral assessment swallows the requirements of Section 2; it says that both stacks apply at once and that the provider of the product covers both. The second is a choice, not a duty: he may integrate the testing and reporting processes, the information and the documentation on the product into the documentation and procedures the sectoral legislation already prescribes. We see two mistakes there. The first is that the AI Act file is built beside the existing technical file, with two versions of the same risk analysis that drift apart after two releases; that is exactly the duplication paragraph 2 seeks to avoid. The second is that the integration happens but cannot be found. Whoever enters the sectoral conformity assessment of Article 43(3) must be able to point, per requirement of Articles 9 to 15, to where in the existing file the answer sits. Integrating is therefore not merging into invisibility; it is a cross-reference per requirement, and that is the form in which the choice of paragraph 2 actually saves work.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6(1); Article 9(1) and (2); Article 16, point (a); Article 40(1); Article 43(3) and (4); Annex I, Section A","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":"editorial"}},{"kind":"recommended_action","text":"Record once, per high-risk system, what you regard as the generally acknowledged state of the art, with the sources: which harmonised standards or common specifications you apply, which of them you do not apply and why, and which evaluation method, benchmark or test set you use for this application area. Attach a fixed re-assessment moment to it, for instance annually and at every release, and hang that record on the risk management file of Article 9 rather than on a separate document; paragraph 1 designates that file as the instrument through which compliance is assessed. Note against which intended purpose each requirement of Articles 9 to 15 has been met, so that a change of intended purpose visibly touches the whole series. If your system sits in a product also covered by Section A of Annex I, make the choice of paragraph 2 explicit before you start and record who made it: one combined file or two files. If you combine, build a cross-reference table that points, per requirement of Section 2, to where in the existing technical file the answer sits, and let that table travel through the sectoral assessment. If you keep two files, record who keeps them in step and on which change both are updated.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6(1); Article 9(1) and (2); Article 16, point (a); Article 40(1); Article 43(3) and (4); Annex I, Section A","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":"editorial"}}],"legal_status":"upcoming","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-8-compliance-with-requirements","label":"Open the human explanation"},{"relation":"official_source","href":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","label":"Article 8 on EUR-Lex"},{"relation":"public_page","href":"/en/ai-act/artikel/8","label":"Read Article 8 in the AI Act Explorer"}],"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":"2026-09-06T00:00:00.000Z","next_review_due_at":"2027-03-05T00:00:00.000Z","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"}]},"links":{"self":"https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-8-compliance-with-requirements&lang=en","alternate":"https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-8-compliance-with-requirements&lang=en&format=jsonld","licence":"https://www.praxikon.com/nl/legal/terms"}}