IA-ACT

The European AI Act

First binding and harmonized legal framework in the world dedicated to artificial intelligence

European regulation is directly applicable in all Member States

Risk-based approach used

Objective: to reconcile innovation, safety, fundamental rights, and trust

Key Dates

April 2021

Proposition du règlement IA par la Commission européenne

December 2023

Final political adoption of the text

2024–2025

Transition phase: preparation, guidelines, authorities

August 2, 2026

Full and mandatory application in the EU

Concerned Actors

The regulation also applies to non-EU actors if the AI produces effects within the Union

Providers

Developers, publishers, and designers of AI systems

Deployers / Users

Companies and administrations using AI

Importers & Distributors

Responsible for placing systems on the market

Control Authorities

National and European supervision authorities

Obligations —Providers/suplliers

Classify the system according to risk level

Design in accordance with the requirements of the regulation

Provide technical documentation and traceability

Conducting conformity assessments prior to placing products on the market

Post-marketing
surveillance

Obligations — Deployers/Users

Use AI in accordance with its intended purpose
Put in place human supervision
Manage risks and incidents related to systems
Inform users when required

ISO/IEC 42001 – AI management system

The ISO/IEC 42001 standard provides a structured framework for AI system governance, facilitating risk management, documentation, and continuous improvement
It represents a relevant methodological starting point, but does not in itself constitute proof of legal compliance with the AI regulation

Obligations — Importers & Distributors

Cooperate with the authorities during
inspections

Inform users when required

Regarding individuals

The AI Regulation does not apply to natural persons using an AI system for strictly personal and non professional purposes

An individual may be classified as a deployer when their
use exceeds the private sphere

What will change from August 2, 2026

Mapping

Requirement to identify and classify AI systems by risk level

Integrated compliance

Integrate AI in accordance with GDPR, cybersecurity, and data governance requirements

Responsibility

Increased responsibilities for user companies

Transparency

Enhanced information and documentation requirements for high risk AI (mainly established by the supplier prior to placing on the market or putting into service)

Sanctions

Significant financial penalties of up to 7% of global turnover or €35 million in the event of non-compliance

Risk-based approach — Four levels

The diagram shows the risk hierarchy and the main implications for each level.

Details by risk level

Unacceptable

• Behavioral manipulation (AI that analyzes your emotions and adapts messages to push you to buy something without you realizing it)

• Exploitation of vulnerabilities.

→ • Mass biometric recognition (permanent surveillance of crowds without any specific legal reason)

Prohibited

High risk

• Recruitment (AI that sorts resumes or ranks candidates for a position)

• Healthcare (AI that assists in making medical diagnoses)

• Education (a system that ranks students according to their performance)

• Justice (AI that helps estimate the risk of recidivism)

• Essential services permitted under strict conditions (data governance, human
supervision, documentation).

Limited risk

• Chatbots,
• content generators
→primary obligation of transparency (informing the user)

Minimal risk

• Office AI, games,
• filters,
→simple recommendations
free use, without specific obligations

Impact on businesses & next steps

• A new layer of compliance to anticipate now
• Convergence of GDPR, AI, cybersecurity, and risk governance

• A key role for lawyers, DPOs, and compliance officers
• An increase in AI audits and controls

Starting August 2, 2027

The obligations applicable to high-risk AI systems are fully deployed for the relevant systems in Article 6(1) and Annex III

• Deadline for suppliers of general-purpose AI models (GPAIs) already on the market before August 2, 2025, to be fully compliant with the requirements of the AI Act

• Completion of the gradual rollout of the regulation, with full implementation planned for this date, except for a few very large-scale public IT systems that have been granted a longer deadline, including: the Schengen Information System (SIS), the Visa Information System, national digital health systems that centralize population data, etc