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Direct answer

What obligations does the provider of an AI system have under Annex III of the AI Act?

Your question is about Annex III: the eight areas separately. 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 the intended purpose of the AI system falls within one of the eight areas listed in Annex III: biometrics, critical infrastructure, education and vocational training, employment and workers management, access to essential private and public services, law enforcement, migration and border control management, or administration of justice and democratic processes.
  • Classification follows Article 6(2). For points 1, 6 and 7 the text adds the condition that the use is permitted under relevant Union or national law. We read that condition as meaning that a prohibition under Article 5 comes before the question whether the system is high-risk; that is our reading and not the literal text, which states the condition without naming the order.
  • The duty rests on the provider, but the role can shift. Under Article 25(1) a distributor, importer, deployer or third party becomes a provider itself where it puts its name or trademark on the system, makes a substantial modification, or changes the intended purpose such that the system becomes high-risk under Article 6. From that moment it carries the mapping to a point of Annex III itself.
  • Article 6(3) takes a system listed in Annex III back outside high-risk where it does not pose a significant risk of harm to health, safety or fundamental rights, including by not materially influencing the outcome of decision making, and one of four conditions is met: the system performs a narrow procedural task, it improves the result of a previously completed human activity, it detects decision making patterns or deviations from prior patterns without replacing or influencing the previously completed human assessment without proper human review, or it performs a preparatory task to an assessment relevant for the purposes of the use cases listed in Annex III. A system that performs profiling of natural persons is always high-risk.
  • The derogation is not free. Article 6(4) requires a provider who considers that a system referred to in Annex III is not high-risk to document its assessment before the system is placed on the market or put into service, subjects that provider to the registration obligation in Article 49(2), and requires it to provide the documentation to national competent authorities on request.

First step: Map every system to a point of Annex III.

Annex III of the AI Act covers the eight areas separately. Annex III names eight areas in which an AI system can be high-risk under Article 6(2). This object publishes those eight areas as separate objects, so that a question about recruitment, assessment, creditworthiness or border control lands on the point that names it rather than on the list as a whole. The duty sits with the provider of an AI system. 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. Map every system to a point of Annex III. Determine per AI system which of the eight areas and which lettered subpoint the intended purpose touches, or establish with reasons that no point applies. Then run the Article 6(3) test and record the outcome as Article 6(4) requires. Do so at the level of the intended purpose and not at the level of the department or the sector.
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

    • Annex III, points 1 to 8
    • Article 7(1) and (3)
    • Article 5(1)(f), Article 27(1), Article 86(1), Article 111(2) and Annex III
    • Article 6(2)-(4), Article 25(1), Article 49(2) and Annex III

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