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ObligationApplicablev1.0.0

Article 111(2): legacy high-risk systems and the 2 August 2030 date

High-risk AI systems placed on the market or put into service before the date of application of Chapter III, since the Digital Omnibus 2 December 2027 for Annex III systems and 2 August 2028 for Annex I systems, come under the high-risk requirements of that Chapter only once their design is significantly changed as from that date. This is not an exemption from the whole Regulation: Article 4 and Article 50 keep running. For systems intended to be used by public authorities the carve out falls away entirely: their providers and deployers must in any case comply with the requirements and obligations by 2 August 2030.

The official source remains authoritative. This is general information about obligations and not legal advice. See this object on the map

Address and citation

This object has an address of its own that is never renamed or reused. Store the identifier in your own file, not the title or the link.

Identifier
praxikon:eu:ai-act:obligation:article-111-legacy-public-systems
Payload hash (sha256)
f6d9b4b81b0a9ef37eec8fdd812d98a712cc1688491f8db5c61b8a857ee419e4

Citation line

Praxikon, "Article 111(2): legacy high-risk systems and the 2 August 2030 date", praxikon:eu:ai-act:obligation:article-111-legacy-public-systems@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-09-06T00:00:00.000Z, sha256 f6d9b4b81b0a9ef37eec8fdd812d98a712cc1688491f8db5c61b8a857ee419e4
Version
1.0.0
Legal time (effective_at)
27 July 2026
Knowledge time (known_at)
14 August 2026
Closed on
Not closed
Application date
2 August 2030
Topics
high-risk, timeline

Review status: Placed against the official source (14 August 2026). Next check due by 10 February 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

Who must act and who is affected

On an obligation the addressee is recorded separately from the party that is merely affected. That difference decides who a supervisory authority addresses and who has work to do without the duty resting on them.

Duty holder

Affected actor

Oversight

Not recorded on this object.

Evidence owner

What this object links to

Every relation appears below as a path: from the source with its locator, through the conditions and exceptions of the object carrying the relation, to the consequence. A locator belongs to a statement in the data and not to a relation, so the source is the source anchor of the carrying object.

Who carries the duty

2 of 2 shown

The duty rests on this role. A supervisory authority addresses this role when it is not met.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

Who is affected without being the addressee

3 of 3 shown

This role is practically affected without being the addressee: it receives the information, has to cooperate, or absorbs the consequences in its own process.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

Who owns the evidence

2 of 2 shown

This duty holder creates, maintains and can produce the evidence.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

What has to be done

2 of 2 shown

This is what concretely has to be done under the obligation.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

What has to be recorded

1 of 1 shown

This is what has to be in the file to show that the action was carried out.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

What keeps it in place

1 of 1 shown

This is what keeps compliance in place over time, periodic or event-driven.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

Public tools

1 of 1 shown

This is the public route a reader can actually use.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

Changes recorded here

3 of 3 shown

This is a dated change in the rules that touches the object.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

What points at this object

Objects hanging off this obligation

5 of 5 shown

The object belongs to this obligation. The source line it hangs off sits there.

  1. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to every high-risk system relying on the transitional rule, from the cut off date for its route: 2 December 2027 for Annex III, 2 August 2028 for Annex I. Continuous, per change, without a deadline of its own. The assessment belongs before the change, because once it is live the switching moment has already passed.

    Relation recorded on: Assess for every design change whether it is significant

    Consequence

  2. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies once it is established that a high-risk system is intended to be used by public authorities. The 2 August 2030 deadline applies to that group regardless of when the system reached the market and regardless of whether the design changes. To be revisited when the system is replaced, phased out or supplied to a different customer group.

    Relation recorded on: Plan compliance for legacy public sector systems by 2 August 2030

    Consequence

  3. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Review gate on a design change

    Consequence

  4. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Transition register of legacy high-risk systems

    Consequence

  5. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Full text of Article 111

    Consequence

What this object states

Official fact

Attributable to a named primary source, with a locator. Where they differ, the official source prevails.

  • Without prejudice to the application of Article 5 as referred to in Article 113, third paragraph, point (a), this Regulation shall apply to operators of high-risk AI systems, other than the systems referred to in paragraph 1 of this Article, that have been placed on the market or put into service before the date of application of Chapter III referred to in Article 113, only if, as from that date, those systems are subject to significant changes in their designs. In any case, the providers and deployers of high-risk AI systems intended to be used by public authorities shall take the necessary steps to comply with the requirements and obligations laid down in this Regulation by 2 August 2030.

  • Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5), applies from 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III, and from 2 August 2028 as regards AI systems classified as high-risk pursuant to Article 6(1) and Annex I.

    • Locator: Amended Article 113 application datespraxikon:eu:ai-act:source:reg-eu-2026-1744Open official source

  • Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, that have been placed on the market before 2 August 2026 shall take the necessary steps in order to comply with Article 50(2) by 2 December 2026.

  • The grace period in paragraph 2 applies where the type and model of an AI system has already been placed on the market. If at least one individual unit was lawfully placed on the market or put into service before the cut off date, the grace period also covers other units of the same type and model, which may be offered without additional obligations, requirements or mandatory additional certification, as long as the design remains unchanged. On a significant change to the design after the cut off date the provider must fully comply with all relevant provisions applicable to high-risk AI systems, including the conformity assessment requirements.

    • Locator: Recital 39 of Regulation (EU) 2026/1744praxikon:eu:ai-act:source:reg-eu-2026-1744Open official source

Our interpretation

Our own reading. It can change without the law changing, and it is not the position of a supervisory authority.

  • In practice this provision is read exactly the wrong way round. Executives hear that existing systems are left alone and conclude that nothing is needed until well into the 2030s. That is wrong in two ways. For a public sector organisation the second sentence gives no escape but a deadline, and it applies whether or not you change anything about the system. And for everyone the transitional rule concerns only the high-risk requirements: Article 4 has been running since February 2025 and Article 50 since August 2026, with legacy generative systems having only until 2 December 2026 to get the machine-readable marking of Article 50(2) in order. The first sentence, moreover, is not a resting place but a switch. As soon as the design is significantly changed you must comply fully with what applies to high-risk systems, the conformity assessment first of all; those duties do follow the shifted calendar of 2 December 2027 and 2 August 2028. That switching moment rarely arises at a time you choose: it arises on a supplier update, a migration or a new data source. Two things therefore matter more than the date itself. You need to know when the first unit of each type and model reached the market, because that is the decisive date and without it you cannot later show which track a system was on. And you need a moment in your change process at which someone assesses whether a change is significant, before it goes live.

Recommended step

A practical step we consider appropriate. Not an obligation following from the Regulation.

  • Determine per type and model of your high-risk AI systems when the first unit was placed on the market or put into service, and whether the system is intended to be used by public authorities. Record that determination with a date and a reasoning, and note which route applies, because that decides whether your cut off is 2 December 2027 or 2 August 2028. For the systems intended for public authority use, set a plan towards 2 August 2030 that counts back from the conformity assessment and the registration, not from the end date. Also build into your change and release process a review moment at which someone records whether an intended design change is significant, before the change goes into production. Separately, check whether Article 111(4) catches you: if so you have until 2 December 2026 for the marking under Article 50(2).

When this applies

  1. 1The transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
  2. 2The transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
  3. 3Applies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
  4. 4The grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
  5. 5Applies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.

When this does not apply

  • Systems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

Referring to this object

Citation block

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "Article 111(2): legacy high-risk systems and the 2 August 2030 date",
praxikon:eu:ai-act:obligation:article-111-legacy-public-systems@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0),
effective_at 2026-07-27T00:00:00.000Z, known_at 2026-08-14T00:00:00.000Z,
sha256 f6d9b4b81b0a9ef37eec8fdd812d98a712cc1688491f8db5c61b8a857ee419e4,
https://www.praxikon.com/en/verkenner/obligation/article-111-legacy-public-systems
(https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-111-legacy-public-systems&effective_at=2026-07-27&known_at=2026-08-14&lang=en, accessed 2026-09-21)

Short form

praxikon:eu:ai-act:obligation:article-111-legacy-public-systems@1.0.0 (sha256 f6d9b4b8)

BibTeX

@misc{praxikon-eu-ai-act-obligation-article-111-legacy-public-systems-1-0-0,
  author       = {{Praxikon}},
  title        = {Article 111(2): legacy high-risk systems and the 2 August 2030 date},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:obligation:article-111-legacy-public-systems},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.2.0, schema 1.5.0},
  note         = {effective_at 2026-07-27T00:00:00.000Z; known_at 2026-08-14T00:00:00.000Z; sha256 f6d9b4b81b0a9ef37eec8fdd812d98a712cc1688491f8db5c61b8a857ee419e4},
  url          = {https://www.praxikon.com/en/verkenner/obligation/article-111-legacy-public-systems},
  urldate      = {2026-09-21},
  language     = {en}
}

CSL JSON

[
  {
    "id": "praxikon:eu:ai-act:obligation:article-111-legacy-public-systems@1.0.0",
    "type": "dataset",
    "title": "Article 111(2): legacy high-risk systems and the 2 August 2030 date",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "1.0.0",
    "number": "praxikon:eu:ai-act:obligation:article-111-legacy-public-systems",
    "URL": "https://www.praxikon.com/en/verkenner/obligation/article-111-legacy-public-systems",
    "language": "en",
    "issued": {
      "date-parts": [
        [
          2026,
          8,
          14
        ]
      ]
    },
    "accessed": {
      "date-parts": [
        [
          2026,
          9,
          21
        ]
      ]
    },
    "note": "dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0; schema 1.5.0; effective_at 2026-07-27T00:00:00.000Z; known_at 2026-08-14T00:00:00.000Z; sha256 f6d9b4b81b0a9ef37eec8fdd812d98a712cc1688491f8db5c61b8a857ee419e4; retrieved_from https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-111-legacy-public-systems&effective_at=2026-07-27&known_at=2026-08-14&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

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For agents and integrations

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