DepthThe conclusion and your first steps
Direct answer
We are a public-sector organisation using AI. What needs to be in place?
You describe: A municipality, executive agency or other public body using AI towards citizens, for example in benefits, enforcement or services. Likely role: body governed by public law (deployer).
This applies now
- Article 4: AI literacyApplicable
- Article 50: transparencyApplicable
Coming up
- Article 27: FRIAfrom 2 December 2027
- Annex III: high-risk AIfrom 2 December 2027
For public bodies the FRIA duty (Article 27) comes on top of classification. It follows the high-risk timeline to 2 December 2027, but the algorithm register, transparency and AI literacy matter now.
Your first actions
- Map the affected groups and their specific risks of harm. Name the categories of natural persons and groups likely to be affected by the use in this specific context, and work out the specific risks of harm per category, using the information the provider supplied under Article 13.
- Justify the Article 6(3) exception against each individual condition. Name which of the four Article 6(3) conditions you invoke, with facts, and separately justify why the system poses no significant risk of harm to health, safety or fundamental rights and does not materially influence the outcome of decision making.
- Take role- and context-specific AI literacy measures. Determine for each role, system and context which combination of instruction, guidance, practice or training is appropriate.
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