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Direct answer

What obligations does the authorised representative, the provider of an AI system and the body governed by public law have under Article 71 of the AI Act?

Your question is about Article 71: EU database for high-risk AI systems listed in Annex III. That obligation applies from 2 December 2027. Whether your system actually falls under it depends on conditions you assess yourself.

You determine this yourself

  • Applies where a provider or authorised representative places an Annex III high-risk AI system on the market or puts it into service and registers itself and that system in accordance with Article 49, where that same party registers a system considered not to be high-risk pursuant to Article 6(3), or where a deployer that is, or that acts on behalf of, a public authority, agency or body registers itself, selects the system and registers its use.
  • Article 49(5) provides that high-risk AI systems referred to in point 2 of Annex III are registered at national level. For those systems the registration therefore does not run through the Article 71 EU database.
  • Paragraph 4 excludes the section referred to in Article 49(4) from public availability. For the systems referred to in points 1, 6 and 7 of Annex III in the areas of law enforcement, migration, asylum and border control management, registration takes place in a secure non-public section of the database, with fewer fields than the full Sections: Section A, points 1 to 10 with the exception of points 6, 8 and 9; Section B, points 1 to 5 and points 8 and 9; Section C, points 1, 2 and 3; and points 1, 2, 3 and 5 of Annex IX. Only the Commission and the national authorities referred to in Article 74(8) have access to those sections. Mind the cross-reference: Article 49(4) was not amended by Regulation (EU) 2026/1744 and therefore still names point 9 of Section B, while Article 1, point (42), of that same Regulation deleted that point. There is nothing left to fill in there.
  • Paragraph 4 additionally excludes the section referred to in Article 60(4), point (c). The main rule there is not a secure section: the provider or prospective provider registers the testing in real world conditions in accordance with Article 71(4), with a Union wide unique single identification number and the information specified in Annex IX. Under the third sentence of paragraph 4 that information is accessible only to market surveillance authorities and the Commission, unless the provider or prospective provider has given consent for also making it accessible to the public. Only for points 1, 6 and 7 of Annex III does the testing registration go into the secure non-public section under Article 49(4), point (d), and for point 2 of Annex III to national level under Article 49(5).

First step: Enter your data in the EU database and keep it up to date.

Article 71 of the AI Act covers EU database for high-risk AI systems listed in Annex III. The provider or, where applicable, the authorised representative enters the data listed in Sections A and B of Annex VIII into the EU database; the deployer who is, or who acts on behalf of, a public authority, agency or body enters the data listed in Section C. Information registered in accordance with Article 49 is publicly available in a user-friendly manner and machine-readable, except for the secure section covering law enforcement, migration, asylum and border control management and the registration of testing in real world conditions. Setting up and maintaining the database itself is a task of the Commission and not a duty of yours. The duty sits with the authorised representative, the provider of an AI system and the body governed by public law. This obligation starts to apply on 2 December 2027.

The conclusion and your first steps

This applies now

  • For this situation, the preparation phase matters most right now.

Coming up

Your first actions

  1. Enter your data in the EU database and keep it up to date. Compile per system the data listed in Sections A and B of Annex VIII, or Section C where you are a public deployer, designate the natural person with the legal authority to register, and make sure the entry stays correct when the status, the Member States or the declaration of conformity change. Section C can only be completed after the provider has entered Section A, because point 3 asks for the URL of that entry.
Read the official sourceChecked on

General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.

Full map for your situation

Source and locator

Every statement above rests on these texts. The locator points to the place in the text, the version and the date say which edition was checked.

  • EU Artificial Intelligence Act 2024/1689

    European Parliament and Council, version original-oj-2024-07-12, checked on , ELI http://data.europa.eu/eli/reg/2024/1689/oj

    Locators in this source

    • Article 71(1)-(6)
    • Annex VIII, Sections A and C
    • Annex VIII, Section B
    • Article 49(4) and Annex IX
    • Article 60(4), point (c), Article 49(4) and (5)
    • Recital 131
    • Article 26(1)-(12)
  • Digital Omnibus on AI 2026/1744

    European Parliament and Council, version official-journal-2026-07-24, checked on , ELI http://data.europa.eu/eli/reg/2026/1744/oj

    Locators in this source

    • Article 1, point (42), deleting Annex VIII, Section B, points 7 and 9
    • Recital 22 of Regulation (EU) 2026/1744
    • Article 1, points (24) and (25), replacing Article 60(1), first subparagraph, and Article 60(2) and inserting Article 60a
    • Article 1, point (40)(b) and (c), replacing Article 113, third paragraph, point (c) and adding point (d)

Dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0, schema 1.5.0.

Execution

Record role and classification for each AI system

The boundary is set out in the rules above. The outcome becomes demonstrable when the facts, role, classification, owner and reassessment are recorded for each system. Embed AI guides that inventory and sets up the AI register. The source interpretation above is separate from this commercial referral by Praxikon to an affiliated brand.

See the AI register approach
Does this answer your question?
Zahed Ashkara, jurist and freelance AI & Privacy Consultant

Behind this page

Zahed Ashkara

Freelance AI & Privacy Consultant, jurist