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EU AI Act guide, updated November 2026

Reg. (EU) 2024/1689
What you need to know

The world's first comprehensive AI regulation. In force since 1 August 2024 and applied in phases: prohibitions from February 2025, GPAI from August 2025 and transparency (Art. 50) from August 2026. The Digital Omnibus postpones high-risk obligations to December 2027 (Annex III) and August 2028 (Annex I). Extraterritorial scope and penalties of up to EUR 35 million or 7% of global turnover.

This document is for information purposes only. It does not constitute legal advice. Dates and obligations are based on Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744 (Digital Omnibus), as in force in November 2026.
35M€ Maximum fine or 7% of global turnover
2 Dec 2027 High-risk Annex III (Digital Omnibus)
4 Risk levels classified
Context

What is the EU AI Act?

Regulation (EU) 2024/1689, adopted on 13 June 2024 and published in the Official Journal on 12 July 2024, is the world's first comprehensive legislation on artificial intelligence. It sets risk-based obligations for providers, importers, distributors and deployers of AI systems operating in the European market. Its scope is extraterritorial: if your AI system has effects on people in the EU, the Regulation applies regardless of where your company is incorporated.

Official timeline

The four phases of the EU AI Act

Phased implementation. Phases 1, 2 and 3 already apply (the third since 2 August 2026). The Digital Omnibus (Regulation (EU) 2026/1744) postpones high-risk obligations: Annex III to 2 December 2027 and Annex I to 2 August 2028.

Risk classification

The four risk levels

The AI Act classifies AI systems according to the risk they pose. The classification determines which obligations apply and from when.

High risk, obligations from Dec 2027 (Annex III)

Obligations for high-risk systems

Annex III systems must meet 10 main obligations by 2 December 2027, following the postponement introduced by the Digital Omnibus (Regulation (EU) 2026/1744). For AI embedded in regulated products under Annex I, the deadline is 2 August 2028. They apply to providers and deployers operating in the EU.

Transparency, in force since Aug 2026

Mandatory transparency (Art. 50)

In force since 2 August 2026. Applies to conversational systems, content generators and emotion recognition systems. Generative AI systems placed on the market before that date have until 2 December 2026 to apply machine-readable marking (Art. 50(2)).

Conversational systems

Chatbots and voice agents must identify themselves as AI at the start of every interaction. Users must know they are not talking to a human being.

HT Kiire and HT Meel Voice, in development, are designed to comply

Synthetic content

AI-generated text, images, audio and video must be labelled as artificially generated content. Mandatory for generators and distributors.

Applies to any GPAI system in production

Emotion recognition

Deployers of emotion recognition systems must inform the people exposed to them. In workplaces and educational settings they are prohibited, except for medical or safety reasons (Art. 5).

Structural human-in-the-loop at HumanosTech
Penalty regime

Administrative penalties

The AI Act sets three levels of penalties. Authorities take company size into account, with adapted caps for SMEs, startups and small mid-caps, but fines can still threaten the viability of a medium-sized company.

35 M€ or 7% of total worldwide annual turnover
Prohibited practices
Non-compliance with the prohibitions in Art. 5. Whichever is higher, the fixed amount or the percentage, applies.
15 M€ or 3% of total worldwide annual turnover
Other obligations
Non-compliance with requirements for high-risk systems, GPAI or other obligations of the Regulation other than Art. 5.
7,5 M€ or 1% of total worldwide annual turnover
Incorrect information
Supplying incorrect, incomplete or misleading information to notified bodies or national competent authorities.
Supervision and resources by country

Supervisory authorities by country

Each Member State designates its own national market surveillance authority. The EU AI Office supervises GPAI models at European level. Select your country to see the competent authority, its designation status and the relevant official resources.

Action plan

Five steps to prepare before December 2027

Whatever the size of your company, these five steps reduce regulatory exposure and provide a foundation for any compliance programme.

1

AI systems inventory

Identify every AI system in use, including those contracted from third parties and those used by teams without IT involvement.

2

Classification by risk level

For each system identified, determine whether it falls into the prohibited, high-risk, limited or minimal category according to the Regulation's criteria.

3

Conformity assessment

For high-risk systems, start the technical documentation, training data analysis and risk management in line with Art. 9.

4

Governance and training

Appoint internal owners for AI compliance. Adopt AI literacy measures (Art. 4) for those who operate or oversee AI systems: following the Digital Omnibus, the Regulation requires taking measures to support it.

5

Legal advice

Involve legal advisers specialised in European AI regulation to validate your strategy, especially for high-risk systems.

HumanosTech and the EU AI Act

Structural compliance, not a configuration option

HumanosTech operates under Estonian legislation and European law (Humanos Tech OÜ, reg. 17179670). Our AI products are designed with EU AI Act compliance built into the architecture, not added afterwards.

HumanosTech does not certify EU AI Act compliance for third-party systems. We offer technical consulting on inventory, classification and governance as a complement to legal advice from a specialised legal professional.
Structural human-in-the-loop: no impactful action is executed without explicit confirmation from a person
Data processed exclusively on servers within the European Union
HT Kiire and HT Meel Voice, in development, will always identify themselves as AI agents at the start of every interaction (Art. 50)
Immutable, auditable logs with timestamp, authoriser identity and full traceability
Company incorporated in Estonia under European law, GDPR-native from day one
In development

HT Kiire

AI chat agent for technical support. It answers with your documentation, citing sources, and helps diagnose incidents. No impactful action is executed without explicit human confirmation. Waiting list open.

Human-in-the-loop Art. 50 compliant Data in the EU Immutable logs
In development

HT Meel Voice

Conversational voice agent for phone support in European environments. It will identify itself as AI at the start of every call (Art. 50) and hand the call to a human with full context. AI is processed in the EU. The voice part is the last stage of the plan; waiting list open.

Art. 50 compliant Waiting list Data in the EU Human escalation Context on handover
In development

HT BiasGuard EU

System for auditing and continuously monitoring bias in AI systems deployed in the EU. Designed to help deployers meet the data governance (Art. 10) and human oversight (Art. 14) obligations, with auditable reports and decision traceability.

Bias auditing Art. 10 and 14 Data in the EU Auditable reports
Official documentation

Official sources and resources

All the information in this guide is based on verified primary sources. For compliance decisions, always consult the official text of the Regulation and the European Commission's guidelines.

Official text

Regulation (EU) 2024/1689, EUR-Lex

Full text in all official EU languages.

eur-lex.europa.eu
European Commission

EU AI Act, official portal

Implementation, governance and up-to-date guidelines from the Commission.

digital-strategy.ec.europa.eu
European Commission

EU AI Office

European AI Office: supervision of GPAI models and coordination between Member States.

EU AI Office
Tool

Compliance Checker

Conformity assessment tool from the Future of Life Institute.

artificialintelligenceact.eu
National authorities

Market Surveillance Authorities

Up-to-date list of the authorities designated in each Member State.

National authorities
BOE, Spain

AI Regulation in the BOE

Official publication of the Regulation in the Spanish Official State Gazette (BOE).

boe.es
Talk to us

Do you need technical guidance on the EU AI Act?

We can help you with your AI systems inventory, risk classification and technical governance. Legal advice requires a specialised legal professional, and we will always say so clearly.

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