KI-Verordnung: Checklist for Providers and Deployers

Checklist of duties in the order of their application dates, from banned practices to high-risk obligations.

Updated 22 October 2026

Providers and deployers of AI systems in the EU can use this checklist in the order of the Act’s application dates. It starts with banned practices, which apply since 2 February 2025. It ends with high-risk duties, which apply from 2 December 2027 (Annex III) and 2 August 2028 (Annex I).

Article 2 lists exclusions. Fines for banned practices reach up to EUR 35 million or 7% of worldwide annual turnover, whichever is higher (Article 99(3)). For most other duties they reach up to EUR 15 million or 3%, whichever is higher (Article 99(4)). Next step: start with phase 1.

Phase 1: Banned practices and AI literacy

Applies since 2 February 2025. The bans on certain intimate and abusive material apply from 2 December 2026.

Check whether any of your AI systems matches a banned practice in Article 5(1), for example harmful manipulation, social scoring, untargeted scraping of facial images or emotion inference at work and in education.
Stop and document any system that matches a banned practice, taking the exceptions in Article 5 into account.
Check systems that generate or manipulate realistic images, video or audio of an identifiable person’s intimate parts or sexually explicit activities without that person’s consent (Article 5(1), point (ba)), and material within Article 2, points (c) and (e), of Directive 2011/93/EU, except where a ‘without right’ defence applies under national law (point (bb)). The ban applies only where this is the system’s intended purpose, or a reasonably foreseeable outcome that adequate safeguards do not prevent (Article 5(1a)).
Take measures to support the AI literacy of your staff and of others who operate or use AI systems on your behalf (Article 4).

Phase 2: General-purpose AI models

Applies since 2 August 2025 to providers of general-purpose AI models. Models placed on the market earlier must comply by 2 August 2027.

Check whether you provide a general-purpose AI model: an AI model with significant generality that can competently perform a wide range of distinct tasks (Article 3(63)).
Draw up and keep up to date technical documentation of the model, and give information to downstream providers (Article 53(1), points (a) and (b)).
Put in place a policy to comply with Union copyright law (Article 53(1), point (c)).
Publish a sufficiently detailed summary of the content used for training (Article 53(1), point (d)).
Check whether the model has systemic risk, which brings further duties (Articles 51 and 55).

Phase 3: Transparency duties (Article 50)

Apply from 2 August 2026. Providers of systems that generate synthetic content and were placed on the market earlier must comply with Article 50(2) by 2 December 2026.

Make AI systems that interact directly with people tell them that they interact with an AI system, unless this is obvious (Article 50(1)).
Mark synthetic audio, image, video and text content in a machine-readable format, so that it is detectable as artificially generated, as far as technically feasible (Article 50(2)). The exceptions in that paragraph apply.
Inform people exposed to an emotion recognition or biometric categorisation system (Article 50(3)).
Disclose deepfakes, and AI-generated text published to inform the public on matters of public interest, subject to the exceptions in Article 50(4).

Phase 4: High-risk obligations for providers

Apply from 2 December 2027 (Annex III) and 2 August 2028 (Annex I). Systems placed on the market or put into service before these dates are covered only after significant design changes (Article 111(2)).

Inventory all AI systems and classify each against Article 6, Annex III and Annex I. Document the assessment if you rely on Article 6(3) (Article 6(4)).
Establish a risk management system that runs over the whole lifecycle (Article 9).
Apply data governance to training, validation and testing data and examine them for possible biases (Article 10).
Draw up technical documentation with at least the Annex IV elements before market placement or putting into service, and keep it up to date (Article 11).
Make the system record events automatically (logs) and keep the logs under your control for at least six months, unless other law provides otherwise (Articles 12 and 19).
Provide instructions for use, so that deployers can interpret the output (Article 13).
Design human oversight so that people can, as appropriate and proportionate, intervene or interrupt the system, for example through a stop button or a similar procedure (Article 14).
Reach and test an appropriate level of accuracy, robustness and cybersecurity (Article 15).
Put a quality management system in place (Article 17).
Complete the conformity assessment before market placement or putting into service, and again after a substantial modification (Article 43).
Draw up the EU declaration of conformity and affix the CE marking (Articles 47 and 48).
Register the system (Article 49) and keep the documentation for ten years after the system is placed on the market or put into service (Article 18).

Phase 5: Duties of deployers of high-risk systems

Apply from 2 December 2027 (Annex III) and 2 August 2028 (Annex I).

Use the system according to its instructions for use (Article 26(1)).
Assign human oversight to natural persons with the necessary competence, training, authority and support (Article 26(2)).
To the extent you control the input data, ensure that it is relevant and sufficiently representative for the intended purpose (Article 26(4)).
Monitor operation on the basis of the instructions for use. If you have reason to consider that use in accordance with the instructions may present a risk within the meaning of Article 79(1), inform the provider or distributor and the market surveillance authority without undue delay, and suspend use (Article 26(5)).
Keep the logs under your control for at least six months, unless other law provides otherwise (Article 26(6)).
Deployers who are employers: before putting into service or using the system at the workplace, inform workers’ representatives and the affected workers (Article 26(7)).
Inform natural persons who are subject to decisions made or assisted by Annex III systems (Article 26(11)).
Use the Article 13 information for a data protection impact assessment where required (Article 26(9)), and assess the impact on fundamental rights where Article 27 applies.

Phase 6: Ongoing duties

Articles 72 and 73 are not listed in Article 113, points (a) to (d), so they apply from the general application date, 2 August 2026. How this fits with the high-risk dates is a question for counsel. The deployer duties below follow the high-risk dates.

Providers: run the post-market monitoring system, which is based on a monitoring plan (Article 72).
Providers report a serious incident to the market surveillance authority immediately after establishing a causal link, or the reasonable likelihood of one, between the system and the incident, and in any event not later than 15 days after becoming aware. Shorter limits apply: not later than 10 days after becoming aware of a death, and not later than 2 days for a widespread infringement or a serious and irreversible disruption of critical infrastructure (Article 73(2) to (4)).
Providers: after a substantial modification, update the technical documentation and repeat the conformity assessment (Articles 11 and 43(4)).
Deployers: after a serious incident, inform first the provider, then the importer or distributor and the market surveillance authorities (Article 26(5)).
Re-run your code and document checks before each release and keep the reports as evidence. A passing scan does not show compliance.

Exclusions, older systems and fine caps

The Regulation does not apply to AI systems used exclusively for military, defence or national security purposes (Article 2(3)). It does not apply to AI systems specifically developed and put into service for the sole purpose of scientific research and development (Article 2(6)), or to research, testing or development before placing on the market or putting into service, except testing in real-world conditions (Article 2(8)). Free and open-source systems are excluded unless they are placed on the market or put into service as high-risk systems or fall under Article 5 or 50 (Article 2(12)). Natural persons who use a system in a purely personal non-professional activity are not bound as deployers (Article 2(10)). For high-risk systems related to products under Annex I Section B legislation, such as motor vehicles, aviation, rail, marine equipment, agricultural vehicles and machinery, only Article 6(1), Article 60a and Articles 102 to 112 apply. Articles 57 to 59 apply only in so far as that legislation integrates the requirements (Article 2(2)).

High-risk systems placed on the market or put into service before the application date are covered only after significant design changes. 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)).

For SMEs, each fine is up to the percentage or amount, whichever is lower (Article 99(6)). For small mid-cap enterprises (SMCs, defined in Article 3(14b)), the same cap applies to fines under Article 99(4) and (5) (Article 99(6a)). The EUR 15 million tier also covers the obligations of providers and operators under Article 25(2) and (4) (Article 99(4), point (da)).

Scanara prepares evidence from your repositories

Scanara reads your connected GitHub repositories and runs rule-based scans for standard AI and machine-learning patterns. It can miss non-standard code. Separately, it generates draft documentation from templates and your assessment answers as evidence for your compliance work. You make the classification decisions.

See how Scanara scans your repos