Direct answer
What does Article 95 of the AI Act say about codes of conduct for voluntary application of specific requirements?
Your question is about Article 95: codes of conduct for voluntary application of specific requirements. That obligation applies today. Whether your system actually falls under it depends on conditions you assess yourself.
You determine this yourself
- Paragraph 1 expressly concerns AI systems other than high-risk AI systems, and the voluntary application to them of some or all of the requirements set out in Chapter III, Section 2. Paragraph 2 is wider and concerns the voluntary application, including by deployers, of specific requirements to all AI systems, on the basis of clear objectives and key performance indicators to measure the achievement of those objectives. Article 95 sits in Chapter X, which is named in none of the three exceptions in the third paragraph of Article 113; the general date of application in the second paragraph therefore governs, 2 August 2026.
- Paragraph 3 sets out who may draw up a code of conduct: individual providers or deployers of AI systems, organisations representing them, or both, including with the involvement of any interested stakeholders and their representative organisations, including civil society organisations and academia. A code may cover one or more AI systems, taking into account the similarity of the intended purpose of the relevant systems.
- Article 95 contains no provision that sets aside, suspends or replaces an obligation under this Regulation. The word voluntary refers to the application of requirements that precisely do not apply to the system concerned, and not to the requirements that do apply. A code of conduct on AI literacy leaves Article 4 untouched, and a code of conduct on transparency leaves Article 50 untouched.
First step: Scope a voluntary code of conduct and separate it from your duties.
Article 95 of the AI Act covers codes of conduct for voluntary application of specific requirements. The AI Office and the Member States encourage and facilitate the drawing up of codes of conduct, including related governance mechanisms, intended to foster the voluntary application to AI systems other than high-risk AI systems of some or all of the requirements set out in Chapter III, Section 2, taking into account the available technical solutions and industry best practices. They also facilitate codes on the voluntary application of specific requirements to all AI systems, on the basis of clear objectives and key performance indicators, with elements such as the Union ethical guidelines for trustworthy AI, assessing and minimising the impact on environmental sustainability, promoting AI literacy, facilitating an inclusive and diverse design, and assessing and preventing the negative impact on vulnerable persons. Codes may be drawn up by individual providers or deployers or by organisations representing them, and in encouraging and facilitating them the specific interests and needs of SMEs, including start-ups, and of small mid-cap enterprises are taken into account; that last group was added by Article 1, point (35), of Regulation (EU) 2026/1744. This article imposes no duty on the organisation and replaces no obligation. This provision concerns the deployer and the provider of an AI system. This provision applies today.
This applies now
Your first actions
- Scope a voluntary code of conduct and separate it from your duties. Choose the paragraph 1 or the paragraph 2 route, name which requirements you apply voluntarily and which you do not, give the code clear objectives and key performance indicators, and keep the voluntary commitments administratively separate from the obligations that continue to apply in full.
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
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