The Annex III high-risk deadline

Annex III lists eight areas where an AI system is presumed high-risk: biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration and border control, and the administration of justice. A system that matches one carries the full set of high-risk duties, including risk management, technical documentation, human oversight, and a conformity assessment before it reaches the market.

Those duties were due to apply from 2 August 2026, the general application date set by Article 113 as published. Regulation (EU) 2026/1744, the Digital Omnibus on AI, deferred that date to 2 December 2027 for stand-alone Annex III systems, and to 2 August 2028 for AI embedded in a product already covered by Annex I legislation. This has been checked directly against the consolidated text of the Regulation on EUR-Lex, which marks the change and cites the amending regulation, so the banner on the homepage counts down to the confirmed date rather than the one originally published.

Every finding this tool produces from Annex III uses the confirmed date. Where a different amendment has been reported but not yet checked against its own primary text, the result screen and the citation index say so explicitly rather than adopting it.