EU AI Act Compliance for Autonomous Systems

The Act has no autonomous-systems category. This site uses the words for AI that reaches the Act through the routes below.

• Autonomous systems are not a category in the Act

  The Act has no category for autonomous systems. Its definition of an AI system speaks of “varying levels of autonomy” (Article 3(1)), and Article 14(3) of a “level of autonomy”. The Act names no self-driving vehicle, drone or robot. This site uses “autonomous systems” for AI in vehicles, unmanned aircraft, robots and machines. Which rules apply depends on the Union product law that covers the product. The next rows give three ways an AI system can be high-risk: through Annex I Section B, through Annex I Section A and through Annex III point 2. Other provisions can apply as well, for example Article 4 (AI literacy), Article 5 (prohibited practices), Article 50 (transparency), Article 53 (general-purpose AI models) and the other points of Annex III.

• Section B products: vehicles, unmanned aircraft, rail, marine equipment, machinery

  Annex I Section B lists, for example, motor vehicles (Regulations (EU) 2018/858 and (EU) 2019/2144, items 18 and 19), two- and three-wheel vehicles and quadricycles (item 14), agricultural and forestry vehicles (item 15), the rail system (item 17), marine equipment (item 16), unmanned aircraft and their engines, propellers, parts and equipment to control them remotely under Regulation (EU) 2018/1139 (item 20) and machinery (Regulation (EU) 2023/1230, item 21). Regulation (EU) 2026/1744 moved machinery from Section A to Section B. For AI systems classified as high-risk under Article 6(1) and related to such products, only Article 6(1), Article 60a and Articles 102 to 112 apply. Articles 57, 58 and 59 apply only in so far as the requirements for high-risk AI systems have been integrated in that Union harmonisation legislation (Article 2(2)). Articles 9 to 15, 17, 26 and 99 are not among the provisions that apply. Article 2(2) is limited to AI systems classified as high-risk under Article 6(1); it does not restrict, for example, Article 4 or Article 5. The overview page for autonomous systems lists what reaches these products instead.

• What reaches Section B products instead

  Articles 102 to 109 amend the Section B laws, other than the Machinery Regulation. When delegated acts, implementing acts or detailed measures are adopted under them concerning AI systems which are safety components, “the requirements set out in Chapter III, Section 2” of the Act “shall be taken into account”. Examples are Article 107 for Regulation (EU) 2018/858 and Article 109 for Regulation (EU) 2019/2144. These articles apply from 27 July 2026 (Article 113, point (d)). Regulation (EU) 2026/1744 adds a similar rule to Regulation (EU) 2018/1139 (its Article 2). For machinery it requires the Commission to adopt delegated acts under Regulation (EU) 2023/1230 that reflect Chapter III, Section 2 and Articles 17, 19, 72 and 73 of the Act for AI systems classified as high-risk under Article 6(1). Those delegated acts must apply by 2 August 2028 (its Article 3). Member States may allow real-world testing of such systems outside regulatory sandboxes, to assess conformity with Articles 8 to 15 (Article 60a). Article 113 names no separate date for Article 60a. Under the general rule of Article 113 it would apply from 2 August 2026; whether another date applies is a question for counsel.

• Section A products: Chapter III applies to high-risk systems

  Annex I Section A (items 2 to 12) covers toys, recreational craft, lifts, equipment for potentially explosive atmospheres, radio equipment, pressure equipment, cableway installations, personal protective equipment, appliances burning gaseous fuels, medical devices and in vitro diagnostic medical devices. An AI system is high-risk under Article 6(1) where it is intended to be used as a safety component of such a product, or is itself such a product, and the product must undergo a third-party conformity assessment under that legislation. A third-party conformity assessment required solely due to risks other than risks to health and safety, such as the distribution of radio spectrum or electromagnetic interference that do not affect health and safety, does not meet that condition (Article 6(1c)). The requirements for these systems apply from 2 August 2028 (Article 113, point (c)(ii)). Article 2(13) allows the application of specific requirements in Articles 9 to 15 and 17 to 25 to be limited, where and to the extent that Section A legislation lays down requirements providing an equivalent or higher level of protection and the limitation does not reduce the overall level of protection. The Commission is to adopt delegated acts on this by 2 August 2027.

• Annex III point 2: road traffic, utility supply and digital infrastructure

  Annex III point 2 covers AI systems intended to be used as safety components in the management and operation of critical digital infrastructure, road traffic, or in the supply of water, gas, heating or electricity. The text of Annex III names no vehicle, aircraft, drone or robot. Whether a given system is a safety component in one of these areas is a question for counsel. The requirements for these Annex III uses apply from 2 December 2027 (Article 113, point (c)(i)).

• Article 6(3) can take a system out of Annex III

  A system under point 2 is high-risk under Article 6(2). Under Article 6(3) it is not high-risk if it does not pose a significant risk of harm to health, safety or fundamental rights. That includes not materially influencing the outcome of decision making. The Act applies this exception where any of the following conditions is fulfilled (Article 6(3), points (a) to (d)). The system is intended to perform a narrow procedural task. Or it is intended to improve the result of a previously completed human activity. Or it is intended to detect decision-making patterns or deviations from prior decision-making patterns and is not meant to replace or influence the previously completed human assessment, without proper human review. Or it is intended to perform a preparatory task to an assessment relevant for the use cases listed in Annex III. How these conditions combine with the significant-risk test is a question for counsel. The system is always high-risk where it performs profiling of natural persons. Profiling is defined by Article 4(4) GDPR (Article 3(52)). A provider that relies on the exception documents its assessment before the system is placed on the market or put into service. It must also register the system (Article 6(4), Article 49(2)).

• Only safety components are covered

  A safety component is 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. A component fulfils a safety function where its intended purpose is to prevent or mitigate risks to health and safety of persons or property (Article 3(14)). AI systems that are 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 (Article 6(1a)). AI systems the failure or malfunctioning of which would endanger health and safety do qualify (Article 6(1b)). Whether a given control, navigation or convenience function is a safety component is a question for counsel.

The provider develops an AI system, or has it developed, and places it on the market or puts it into service under its own name or trademark (Article 3(3)). Putting into service includes supply for the provider’s own use (Article 3(11)). For a safety component of a Section A product, the product manufacturer is the provider where the system is placed on the market together with the product under the manufacturer’s name or trademark, or is put into service under that name or trademark after the product has been placed on the market (Article 25(3)). A fleet operator, plant operator or road authority that uses a system under its authority is a deployer (Article 3(4)). A deployer becomes the provider in three cases. It puts its name or trademark on a high-risk system already on the market, without prejudice to contractual arrangements stipulating that the obligations are otherwise allocated. It makes a substantial modification to such a system that leaves it high-risk. Or it changes the intended purpose of a non-high-risk system so that it becomes high-risk (Article 25(1)). The provider that initially placed the system on the market or put it into service is then no longer considered the provider of that specific system, and must closely cooperate with the new provider (Article 25(2)). This does not apply where the initial provider clearly specified that its system is not to be changed into a high-risk AI system.

For high-risk systems under Annex I Section A and Annex III point 2, providers must ensure that their systems meet the requirements of Section 2 of Chapter III, Articles 8 to 15 (Article 16, point (a)), and meet the other obligations of Article 16. For Section B products these do not apply (Article 2(2)).

• Art. 9
  Risk management system

  A continuous iterative process over the lifecycle, with testing against prior defined metrics and probabilistic thresholds appropriate to the intended purpose.

• Art. 10
  Data and data governance

  Training, validation and testing data sets that meet the quality criteria of Article 10, including an examination for possible biases.

• Art. 12
  Logging by design

  The system must technically allow for the automatic recording of events (logs) over its lifetime.

• Art. 13
  Instructions for use

  Information that lets deployers interpret the output and use it appropriately, including the declared level of accuracy and its metrics.

• Art. 14
  Human oversight by design

  Measures that let natural persons effectively oversee the system while it is in use.

• Art. 15
  Accuracy, robustness and cybersecurity

  An appropriate level, achieved consistently throughout the lifecycle. The levels of accuracy and the relevant accuracy metrics are declared in the instructions for use.

• Art. 17
  Quality management system

  Written policies, procedures and instructions covering the aspects listed in Article 17(1), implemented in proportion to the size of the provider’s organisation (Article 17(2)).

• Art. 43(2), (3)
  Conformity assessment

  For Section A products the provider follows the conformity assessment procedure required by the relevant Union harmonisation legislation. The requirements of Section 2 are part of that assessment, and the quality management system of Article 17 is also assessed (Article 43(3)). Notified bodies notified under Section A legislation are to apply for designation under the AI Act by 28 January 2028 (Article 43(3)). For the systems in points 2 to 8 of Annex III, which include point 2, the provider follows the procedure based on internal control (Annex VI), which does not provide for a notified body (Article 43(2)).

• Art. 16, 49(1), (5)
  EU declaration, CE marking and registration

  The provider draws up an EU declaration of conformity and affixes the CE marking (Article 16, points (g) and (h)). Article 49(1) requires registration in the EU database for Annex III systems with the exception of point 2. Article 49(5) provides that systems referred to in point 2 of Annex III are registered at national level.

• Art. 72, 73
  Post-market monitoring and serious incidents

  The provider establishes and documents a post-market monitoring system (Article 72(1)) and reports serious incidents to the market surveillance authorities (Article 73).

• Art. 26(1), (2)
  Use as instructed, assign oversight

  Deployers take appropriate technical and organisational measures to use the system in accordance with the instructions for use. They assign human oversight to natural persons who have the necessary competence, training and authority.

• Art. 26(4)–(6)
  Input data, monitoring and logs

  To the extent they control the input data, deployers ensure it is relevant and sufficiently representative. They monitor the operation of the system on the basis of the instructions for use. They keep the logs under their control for at least six months, unless provided otherwise in applicable Union or national law.

• Art. 26(11)
  Inform the persons concerned

  Deployers of high-risk Annex III systems that make or assist decisions related to natural persons inform them that they are subject to the use of the system, without prejudice to Article 50 (Article 26(11)).

• Art. 27(1)
  No fundamental rights impact assessment for point 2

  Article 27(1) requires an assessment of the impact on fundamental rights before a high-risk AI system referred to in Article 6(2) is deployed by the deployers it names, “with the exception of high-risk AI systems intended to be used in the area listed in point 2 of Annex III”. Section A products are classified under Article 6(1), not Article 6(2). For any other high-risk Annex III system it uses, a deployer checks Article 27(1) separately.

• Art. 49(3), (5), 86(1)
  No deployer registration and no right to explanation for point 2

  Article 49(3) excludes systems listed in point 2 of Annex III from the registration of the deployer and of the use in the EU database. Article 49(5) provides that they are registered at national level. Article 86(1) gives the right to explanation for Annex III systems “with the exception of systems listed under point 2”.

• Dates

  Section A: the requirements of Chapter III, Sections 1 to 3, apply to AI systems classified as high-risk under Article 6(1) from 2 August 2028 (Article 113, point (c)(ii)). Annex III point 2: from 2 December 2027 (point (c)(i)). Section B: Articles 9 to 15 have no date because they do not apply (Article 2(2)); Articles 102 to 110 apply from 27 July 2026 (point (d)). A system placed on the market or put into service before the date of application is covered only if its design changes significantly afterwards. In any case, providers and deployers of high-risk systems intended to be used by public authorities must take the necessary steps to comply by 2 August 2030 (Article 111(2)).

• Fines

  Providers must ensure that their high-risk systems meet the requirements of Section 2 of Chapter III, which includes Articles 9 to 15 (Article 16, point (a)). A breach of the provider obligations in Article 16 or of the deployer obligations in Article 26 can be fined. The fine is up to EUR 15 million or, for an undertaking, up to 3% of its total worldwide annual turnover for the preceding financial year, whichever is higher (Article 99(4), points (a) and (e)). For SMEs, including start-ups, each fine is up to whichever of the two is lower (Article 99(6)). The same applies to small mid-cap enterprises (Article 3(14b), Article 99(6a)). Each Member State lays down rules on to what extent administrative fines may be imposed on public authorities and bodies established in that Member State (Article 99(8)). For Section B products, Article 99 is not among the provisions that Article 2(2) lists as applying.

• Reach and limits of the Act

  The Act applies to providers and deployers established or located in a third country where the output produced by the AI system is used in the Union (Article 2(1), point (c)). It does not apply to areas outside the scope of Union law, and it does not affect the competences of the Member States concerning national security (Article 2(3)). It does not apply to AI systems where and in so far they are placed on the market, put into service, or used with or without modification exclusively for military, defence or national security purposes (Article 2(3)). The Act does not apply to AI systems or AI models, including their output, specifically developed and put into service for the sole purpose of scientific research and development (Article 2(6)). It does not apply to research, testing or development activity before a system is placed on the market or put into service. Testing in real-world conditions is not covered by that exclusion (Article 2(8)). AI systems released under free and open-source licences are outside the Act. That exclusion does not apply if they are placed on the market or put into service as high-risk AI systems, or if they fall under Article 5 or 50 (Article 2(12)). The Act does not apply to the obligations of deployers who are natural persons using AI systems in the course of a purely personal non-professional activity (Article 2(10)).

• No autonomy levels, operating domains or numeric thresholds

  The Act defines no levels of autonomy and uses no term such as operational design domain, remote operator or event data recorder. It names no accuracy value, response time, redundancy level or technical standard. Providers set the metrics for testing (Article 9(8)) and declare the accuracy levels and metrics in the instructions for use (Article 15(3)). The Act itself names no harmonised standard. High-risk systems that conform to harmonised standards published in the Official Journal are presumed to conform to the requirements of Section 2, to the extent those standards cover them (Article 40(1)). The Commission is to develop guidelines on the practical application of the requirements and obligations in Articles 8 to 15, 25 and 26 (Article 96(1), point (a)) and on the relationship of the Act with the Annex I legislation (point (e)). Article 42 adds presumptions of conformity with Article 10(4) (paragraph 1) and with the cybersecurity requirements of Article 15 (paragraphs 2 and 3). For Section A products the Commission is also to publish guidelines on Article 8(2), Article 9(10) and Article 17(3) by 1 August 2027 (Article 96(1), point (g)).

• Other law applies alongside the Act

  The Act is without prejudice to the rules of other Union legal acts on consumer protection and product safety (Article 2(9)), and Union data protection law continues to apply (Article 2(7)). The Section B laws keep their own rules, which this page does not describe. Articles 102 to 109 and Regulation (EU) 2026/1744 amend some of them, as shown above.

• Example: one inventory of AI systems

  Example, not an Act requirement: a manufacturer or operator could keep one inventory of its AI systems. It could list for each system the Annex I item or Annex III point, whether it is a safety component, whether Article 6(1) is met, and whether the organisation is provider or deployer.

Each page applies one article to AI in vehicles, unmanned aircraft, robots and machines.

• Article 9 for Autonomous Systems: Risk Management System

  Risk management system for safety-component AI.

• Article 10 for Autonomous Systems: Data and Data Governance

  Data sets, bias examination and special categories of personal data.

• Article 12 for Autonomous Systems: Record-Keeping and Logs

  Automatic logging, who keeps the logs and serious incidents.

• Article 13 for Autonomous Systems: Transparency and Instructions for Use

  Instructions for use and why Article 86 does not cover point 2.

• Article 14 for Autonomous Systems: Human Oversight

  Human oversight, the stop procedure and what the Act does not require.

• Article 15 for Autonomous Systems: Accuracy, Robustness and Cybersecurity

  Accuracy, robustness and cybersecurity.

• Article 17 for Autonomous Systems: Quality Management System

  Quality management system.

• Article 26 for Autonomous Systems: Deployer Obligations

  Deployer obligations for Section A and point 2 systems.

• Article 50 for Autonomous Systems: Transparency and Disclosure

  Transparency duties for chatbots and generated content.

• Article 53 for Autonomous Systems: Obligations of General-Purpose AI Model Providers

  Providers of general-purpose AI models.

• Annex I High-Risk AI Systems: The Product-Safety Route

  Annex I Sections A and B: which products, which rules apply and what changed for machinery.

• Article 6: High-Risk AI System Classification

  How Article 6 classifies high-risk AI systems, including safety components and the Article 6(3) exception.

• Annex III Deep Dive: All 8 High-Risk Categories

  Point 2 of Annex III in the context of all eight categories.