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ObligationIn forcev1.0.0

Article 6(1a) to (1c): the tightened classification route

The Digital Omnibus inserts three paragraphs into Article 6 that draw the notion of safety component more tightly: which AI systems do not qualify as safety components, which still do despite that exclusion because failure would endanger health and safety, and which mandatory third-party conformity assessment does not count. Paragraph 1a is written for the purposes of the Regulation as a whole and therefore bears on both the Annex I route and Annex III, point 2.

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-6-1bis-1quater-route
Payload hash (sha256)
b1a3c8f90e9a6725cbe17956c5c8b7e1eef30c09b708afd4f0758b446f53b35f

Citation line

Praxikon, "Article 6(1a) to (1c): the tightened classification route", praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route@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 b1a3c8f90e9a6725cbe17956c5c8b7e1eef30c09b708afd4f0758b446f53b35f
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 December 2027
Topics
conformity, high-risk

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

Not recorded on this object.

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

1 of 1 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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    • Condition | any ofApplies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity.
    • Condition | allFor the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply.
    • ExceptionParagraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components.
    • ExceptionParagraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b).

    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

1 of 1 shown

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

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    • Condition | any ofApplies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity.
    • Condition | allFor the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply.
    • ExceptionParagraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components.
    • ExceptionParagraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b).

    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

1 of 1 shown

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

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    • Condition | any ofApplies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity.
    • Condition | allFor the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply.
    • ExceptionParagraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components.
    • ExceptionParagraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b).

    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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    • Condition | any ofApplies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity.
    • Condition | allFor the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply.
    • ExceptionParagraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components.
    • ExceptionParagraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b).

    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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    • Condition | any ofApplies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity.
    • Condition | allFor the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply.
    • ExceptionParagraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components.
    • ExceptionParagraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b).

    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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    • Condition | any ofApplies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity.
    • Condition | allFor the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply.
    • ExceptionParagraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components.
    • ExceptionParagraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b).

    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

4 of 4 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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    • Condition | allTo be carried out during the design of a product covered by the Union harmonisation legislation listed in Annex I, Section A, and again on every change to the intended purpose or to the function of the AI component.

    Relation recorded on: Determine and record whether your AI component is a safety component

    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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Reassessment on a change of function or purpose

    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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

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

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Record of the safety component assessment

    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.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 6(1)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Inserted Article 6(1a)-(1c)

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 3(14)

      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: Amended Article 2(2), Article 43(3) and Annex I

      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 the inserted paragraphs

    Consequence

What this object states

Official fact

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

  • Article 6(1) provides: irrespective of whether an AI system is placed on the market or put into service independently of the products referred to in points (a) and (b), that AI system shall be considered to be high-risk where both of the following conditions are fulfilled: (a) the AI system is intended to be used as a safety component of a product, or the AI system is itself a product, covered by the Union harmonisation legislation listed in Annex I; (b) the product whose safety component pursuant to point (a) is the AI system, or the AI system itself as a product, is required to undergo a third-party conformity assessment, with a view to the placing on the market or the putting into service of that product pursuant to the Union harmonisation legislation listed in Annex I.

  • Regulation (EU) 2026/1744 inserts three paragraphs into Article 6. Paragraph 1a: "For the purposes of this Regulation, including paragraph 1 of this Article, AI systems that are solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control shall not qualify as safety components." Paragraph 1b: "Notwithstanding paragraph 1a, AI systems the failure or malfunctioning of which would endanger health and safety shall qualify as safety components." Paragraph 1c: "A product that is required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, shall not be considered as fulfilling the condition in paragraph 1, point (b)."

  • The same Regulation amends the definition in Article 3, point (14). As amended it reads: "safety component" means a component of a product or of an AI system which fulfils a safety function for that product or AI system, or the failure or malfunctioning of which endangers the health and safety of persons or property; for the purposes of this definition, a component fulfils a safety function where its intended purpose is to prevent or mitigate risks to the health and safety of persons or property. Article 3 sits in Chapter I, which under Article 113, third paragraph, point (a), has applied since 2 February 2025. This amended definition therefore operates from the entry into force of the amending Regulation on 27 July 2026 and not only from some later application date.

  • The amended Article 113, third paragraph, point (c), provides that Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5), shall apply from: (i) 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III; and (ii) 2 August 2028 as regards AI systems classified as high-risk pursuant to Article 6(1) and Annex I. The added point (d) provides that Articles 102 to 110 shall apply from 27 July 2026. Annex III, point 2, uses the notion of safety component for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity; that route falls under the 2 December 2027 date.

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

  • The same Regulation moves machinery out of Chapter III. In Annex I, Section A, point 1 (the reference to Directive 2006/42/EC) is deleted and Section B gains point 21: Regulation (EU) 2023/1230 on machinery. The amended Article 2(2) reads that for AI systems classified as high-risk in accordance with Article 6(1) related to products covered by the Union harmonisation legislation listed in Section B of Annex I, only Article 6(1), Article 60a and Articles 102 to 112 shall apply. The amended Article 43(3) adds that the classification of a product as a high-risk AI system in accordance with Article 6(1) does not affect the choice of the conformity assessment procedure provided to manufacturers of products covered by Annex I, Section A, and that those manufacturers are not required to choose a procedure involving third-party conformity assessment only because the product includes a high-risk AI system as a safety component, if the Section A legislation does not require it. The new Article 2(13) provides that specific requirements or obligations under Articles 9 to 15 and 17 to 25 may be limited where Section A legislation provides an equivalent or higher level of protection, and obliges the Commission to adopt delegated acts on this by 2 August 2027.

    • Locator: Amended Article 2(2), Article 43(3) and Annex Ipraxikon: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.

  • What changes in practice is what the discussion is about. Until now it was about whether your product falls under Annex I and whether a third party is involved. Those two questions remain, but a third one belongs in front of them: what function does your AI component actually perform. A recommendation model that optimises when a machine is serviced, or a model that improves throughput on a line, sits in the list in paragraph 1a, and such functions often ended up classified as safety components simply because they ran inside a regulated product. Be careful with quality control as an example: paragraph 1a names only the non-safety related aspects of it, and in many regulated products a vision model that flags deviations is safety QC. Paragraph 1b draws the line: as soon as failure or malfunctioning would endanger health and safety, the exclusion does not count. The question therefore moves from your product file to your failure analysis, and at most providers that analysis is recorded nowhere. Paragraph 1c is narrower: anyone who needed a third party only because of radio spectrum or electromagnetic interference does not meet paragraph 1, point (b), by that route. That paragraph too requires a weighing, because it works only if the third party is mandatory solely on account of those other risks; where your product falls under several Annex I acts, a second act may still satisfy the condition on health and safety grounds. Two things finally that move the stakes. Machinery no longer runs through this route: Regulation (EU) 2023/1230 now sits in Annex I, Section B, and for those products the amended Article 2(2) means Chapter III does not apply at all. And for Section A products the same Regulation pushes the other way: the amended Article 43(3) says expressly that classification under Article 6(1) does not affect the choice of conformity assessment procedure and pushes nobody towards a notified body who was not already headed there. So build your failure analysis as your own file, not as something you will have to put in front of a notified body anyway.

    • Locator: Inserted Article 6(1a)-(1c)praxikon:eu:ai-act:source:reg-eu-2026-1744Open official source
    • Locator: Amended Article 2(2), Article 43(3) and Annex Ipraxikon:eu:ai-act:source:reg-eu-2026-1744Open official source

Recommended step

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

  • This is our recommendation and not a legal duty: paragraphs 1a to 1c are delimiting rules and impose no obligation on anyone. First establish whether your product falls under Annex I, Section A or Section B; for Section B, which now includes machinery, Chapter III stops here. For Section A, record per AI component which function it performs, whether that is a safety function within the meaning of the amended Article 3, point (14), and what happens on failure or malfunctioning. Note which of the three paragraphs you apply and why. Use that file to support your own classification, not because a notified body asks for it: the amended Article 43(3) points the other way. Keep two dates apart: 2 December 2027 for the route via Annex III, point 2, and 2 August 2028 for the route via Annex I.

    • Locator: Inserted Article 6(1a)-(1c)praxikon:eu:ai-act:source:reg-eu-2026-1744Open official source
    • Locator: Amended Article 2(2), Article 43(3) and Annex Ipraxikon:eu:ai-act:source:reg-eu-2026-1744Open official source

When this applies

  1. 1Applies where it must be determined whether an AI system is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and whether that product is required to undergo a third-party conformity assessment. Because paragraph 1a writes itself for the purposes of this Regulation, the delimitation also bears on Annex III, point 2, where the notion of safety component is used for critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity.
  2. 2For the consequences under Chapter III only Annex I, Section A, counts. For products under Section B, including machinery since Regulation (EU) 2023/1230 was moved there, the amended Article 2(2) means that only Article 6(1), Article 60a and Articles 102 to 112 apply.

When this does not apply

  • Paragraph 1a provides that AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Paragraph 1b takes that exclusion back: AI systems the failure or malfunctioning of which would endanger health and safety do qualify as safety components.
  • Paragraph 1c provides that a product required to undergo a third-party conformity assessment solely due to risks other than risks to health and safety, in particular risks relating to the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, is not considered as fulfilling the condition in paragraph 1, point (b).

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 6(1a) to (1c): the tightened classification route",
praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route@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 b1a3c8f90e9a6725cbe17956c5c8b7e1eef30c09b708afd4f0758b446f53b35f,
https://www.praxikon.com/en/verkenner/obligation/article-6-1bis-1quater-route
(https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-6-1bis-1quater-route&effective_at=2026-07-27&known_at=2026-08-14&lang=en, accessed 2026-09-20)

Short form

praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route@1.0.0 (sha256 b1a3c8f9)

BibTeX

@misc{praxikon-eu-ai-act-obligation-article-6-1bis-1quater-route-1-0-0,
  author       = {{Praxikon}},
  title        = {Article 6(1a) to (1c): the tightened classification route},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route},
  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 b1a3c8f90e9a6725cbe17956c5c8b7e1eef30c09b708afd4f0758b446f53b35f},
  url          = {https://www.praxikon.com/en/verkenner/obligation/article-6-1bis-1quater-route},
  urldate      = {2026-09-20},
  language     = {en}
}

CSL JSON

[
  {
    "id": "praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route@1.0.0",
    "type": "dataset",
    "title": "Article 6(1a) to (1c): the tightened classification route",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "1.0.0",
    "number": "praxikon:eu:ai-act:obligation:article-6-1bis-1quater-route",
    "URL": "https://www.praxikon.com/en/verkenner/obligation/article-6-1bis-1quater-route",
    "language": "en",
    "issued": {
      "date-parts": [
        [
          2026,
          8,
          14
        ]
      ]
    },
    "accessed": {
      "date-parts": [
        [
          2026,
          9,
          20
        ]
      ]
    },
    "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 b1a3c8f90e9a6725cbe17956c5c8b7e1eef30c09b708afd4f0758b446f53b35f; retrieved_from https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-6-1bis-1quater-route&effective_at=2026-07-27&known_at=2026-08-14&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

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