For education institutions, EdTech providers and L&D teams using AI for admission, assessment, level assignment or student monitoring.
Annex III point 3 is broader than schools. The guidelines cover formal and non-formal education, vocational training, adult education and programmes that may provide certificates.
The four routes are access/admission/assignment, evaluation of learning outcomes, assessment of education level and monitoring or detecting prohibited student behaviour.
Does the AI influence a natural person’s learning path, assessment or access?
Summary by Praxikon of the draft of 19 May 2026. The draft is not binding; the final guidelines have not yet been published.
The draft separates support for learning from assessment that shapes a learner's path. Admission, marking, level placement and proctoring fall under point 3. Adaptive learning platforms that assess whether a learner has mastered a topic and steer the learning path accordingly fall under point 3(b): the annex expressly mentions steering the learning process. Emotion recognition in education institutions is prohibited except for medical or safety reasons (Article 5(1)(f)), so proctoring that measures stress or emotions runs into that ban.
Falling outside depends on the intended purpose and on the Article 6(3) exception, which never applies to profiling.
The overview of all eight areas and the dates is on Annex III of the AI Act; the Article 6(3) filter is explained in the Commission guidelines on high-risk AI.
AI that determines access to an education or training programme, or assigns a person to a learning path.
AI that evaluates performance, assignments, exams or competencies.
AI that assesses the level of education someone will receive or can access.
AI that monitors or detects prohibited student behaviour during tests.
Check whether your EdTech, assessment or student monitoring falls under Annex III point 3.
Short answers for classification, evidence and next steps under Annex III.
The four routes are access/admission/assignment, evaluation of learning outcomes, assessment of education level and monitoring or detecting prohibited student behaviour. The practical starting question is: Does the AI influence a natural person’s learning path, assessment or access?
This domain page expands the main routes: Access, admission and assignment, Evaluation of learning outcomes, Assessing the appropriate level of education and Student monitoring and prohibited behaviour. For each system, check the intended purpose, the output and the impact on access, rights or safety.
Document the intended purpose, use context, relevant Annex III route, Article 6(3) assessment, any profiling, provider/deployer roles and the required safeguards.