The EU AI Act regulates by risk level: the greater the potential impact on people, the heavier the obligations.
Prohibited Unacceptable risk
Practices banned by the regulation: they cannot be documented or authorised, they must be withdrawn.
Subliminal manipulation, social scoring, mass biometric surveillance.
Stop the practice or redesign the system to exit the prohibited category.
- Key deadline
- Banned since 2 February 2025
- Maximum penalty
- Up to €35M or 7% of global turnover
High risk High risk (Annex III and Annex I)
Systems that affect people's safety or fundamental rights.
AI in HR (CV screening, evaluation), credit scoring and insurance, education, healthcare (diagnosis, triage), justice and borders, critical infrastructure.
Risk management, data quality, technical documentation (Annex IV), traceability, human oversight and robustness. Registration in the EU database for providers.
- Key deadline
- Annex III: 2 August 2026 · Annex I (regulated products): 2 August 2027
- Maximum penalty
- Up to €15M or 3% of global turnover
Transparency Limited risk
Systems that interact with people or generate content: the key is that the user knows.
Chatbots, virtual assistants, AI-generated content, deepfakes.
Disclose the AI interaction, label generated content (including deepfakes) and offer a human intervention mechanism.
- Key deadline
- With the regulation's general regime: 2 August 2026
- Maximum penalty
- General regime: up to €15M or 3%
No specific obligations Minimal risk
Most AI in use: no level-specific obligations.
Spam filters, recommenders, internal process optimisation.
None specific to the level. AI literacy (Article 4) applies across the board.
- Key deadline
- Article 4 in force since 2 February 2025
- Maximum penalty
- No level-specific penalties
Separate branch GPAI models
General-purpose models (like GPT, Claude or Gemini): provider obligations of their own, in parallel to the risk levels.
Models trained at scale that serve many different tasks. Whoever integrates them via API is a deployer, not a GPAI provider.
Technical documentation (model cards), transparency and copyright compliance.
- Key deadline
- Obligations since 2 August 2025 · Fines applicable from 2 August 2026
- Maximum penalty
- Up to €15M or 3% of global turnover