EU AI Act high-risk AI systems (Annex III)
Annex III lists areas where AI is high-risk, such as hiring, credit, education and access to essential services. High-risk systems need risk management, data governance, logging, human oversight and documentation.
Screening questions
- Biometrics: remote biometric identification, biometric categorisation, or emotion recognition (where not prohibited)?
- Critical infrastructure: a safety component in managing digital infrastructure, road traffic, or water, gas, heating or electricity supply?
- Education: deciding admission, evaluating learning outcomes, assessing the level of education, or monitoring students during tests?
- Employment: recruiting or selecting people, deciding promotions or terminations, allocating tasks by behaviour or traits, or monitoring and evaluating workers?
- Essential services: assessing eligibility for public benefits, creditworthiness or credit scores (other than fraud detection), life or health insurance pricing, or triaging emergency calls?
- Law enforcement uses (e.g. assessing the risk of someone becoming a victim or offender, evaluating evidence reliability)?
- Migration, asylum or border control (e.g. assessing risks posed by a person, examining applications)?
- Administration of justice or democratic processes (assisting judicial decisions, or influencing the outcome of an election or referendum)?
If this applies
A use listed in Annex III. Obligations for these apply from 2 December 2027 (moved from 2 August 2026), unless an Article 6(3) exception applies and you document why.
Screen your AI system free (24 questions)
The AI Governance Toolkit Professional ($599) has the EU AI Act risk assessment workbook for each system, plus the AI policy and risk register, ISO/IEC 42001 gap assessment and NIST AI RMF mapping.
Other parts of the EU AI Act
- prohibited AI practices (Article 5)
- high-risk AI in regulated products (Annex I)
- transparency obligations (Article 50)
- general-purpose AI (GPAI) models
- Timeline: when each obligation applies
EU AI Act (Regulation (EU) 2024/1689) as amended by the Digital Omnibus on AI (in force 27 July 2026). Screening questions are our own summary, not legal text. This is a screening aid, not legal advice.