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EU Artificial Intelligence Act: the post-Omnibus timeline, labelling of generative AI, roles, AI in products and high-risk rules for workplace AI.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 1: the new AI Act timeline after the Digital Omnibus

The EU AI Act (EU) 2024/1689 has been amended by the Digital Omnibus (EU) 2026/1744: Annex III high-risk rules move to 2 December 2027 and AI built into products to 2 August 2028. This article sets out the four risk levels, the application dates of each phase and the main changes, to help non-EU companies set priorities.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 2: do AI-generated marketing materials and customer service chatbots need labelling? Article 50 transparency obligations

The Article 50 transparency obligations of the EU AI Act have applied since 2 August 2026, with a marking grace period to 2 December 2026 for existing generative AI systems. Who is responsible for chatbot notices, machine-readable marking and deep fake disclosure, and where non-EU companies using AI for marketing most often get it wrong.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 3: are you a provider or a deployer? Determining your AI Act role

EU AI Act obligations follow your role: provider, deployer, importer, distributor, authorised representative or product manufacturer. Which role Asian ODMs, own-brand companies, software vendors and European subsidiaries most often fall into, and how roles change with rebranding, substantial modification or a change of intended purpose.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 4: AI in machinery now goes through the Machinery Regulation after the Omnibus

The Digital Omnibus moves the Machinery Regulation (EU) 2023/1230 from Section A to Section B of AI Act Annex I. High-risk AI in machinery no longer falls directly under AI Act Chapter III; its requirements will come through a delegated act under the Machinery Regulation, intended to apply by 2 August 2028. What this means for Asian machine tool, automation and robot makers.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 5: is AI for quality inspection or performance optimisation high-risk? Assessing AI built into products

Under AI Act Article 6(1), AI built into a product is high-risk only if it is a safety component and the product requires third-party conformity assessment; this applies from 2 August 2028. The Digital Omnibus adds Article 6(1a) to (1c): AI for quality control or performance optimisation is not a safety component, nor are products assessed by a third party only for radio spectrum or EMC.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 6: your European customer wants AI documents. What should a supplier provide under Article 25(4)?

AI Act Article 25(4) requires high-risk AI providers and suppliers of AI systems, models, tools and components to agree in writing on information, technical access and assistance. The Digital Omnibus names model suppliers explicitly and adds penalties. What suppliers of AI modules, software and components will be asked for, and what they can withhold.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 7: using AI to schedule after-sales engineers may be high-risk AI

Under point 4(b) of Annex III to the AI Act, AI systems that allocate tasks based on individual behaviour or traits, or monitor or evaluate performance, are high-risk from 2 December 2027. Using a Taiwanese equipment maker's European after-sales service, we explain when AI dispatch is high-risk, why profiling defeats the exception, and links to GDPR Article 22 and informing workers.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 8: your European subsidiary uses AI to screen CVs. What is the deployer responsible for?

Under point 4(a) of Annex III to the AI Act, AI systems used for recruitment and selection, screening CVs and evaluating candidates are high-risk from 2 December 2027. Deployer obligations for European subsidiaries using recruitment AI, informing candidates and the right to explanation, and why screening CVs with general-purpose generative AI may make you a provider.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 9: "we are not high-risk". What evidence does the Article 6(3) exception require?

AI Act Article 6(3) lets Annex III AI systems avoid high-risk status where they pose no significant risk, but only in four defined cases, and any system performing profiling is always high-risk. Providers claiming the exception must document the assessment before placing on the market and register in the EU database; authorities can reassess under Article 80, and misclassification can be fined.

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AI Act · 4 Nov 2026

EU AI Act in practice, part 10: the AI literacy obligation has been relaxed, not removed

AI literacy under AI Act Article 4 has applied to providers and deployers of all AI systems since 2 February 2025. The Digital Omnibus changes it from "ensure a sufficient level" to "take measures to support the development" and states that no specific level has to be guaranteed. What changed, what did not, and how it differs from human oversight of high-risk AI.

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AI Act

EU AI Act in practice, part 1: the new AI Act timeline after the Digital Omnibus

EU AI Act in practice, part 2: do AI-generated marketing materials and customer service chatbots need labelling? Article 50 transparency obligations

EU AI Act in practice, part 3: are you a provider or a deployer? Determining your AI Act role

EU AI Act in practice, part 4: AI in machinery now goes through the Machinery Regulation after the Omnibus

EU AI Act in practice, part 5: is AI for quality inspection or performance optimisation high-risk? Assessing AI built into products

EU AI Act in practice, part 6: your European customer wants AI documents. What should a supplier provide under Article 25(4)?

EU AI Act in practice, part 7: using AI to schedule after-sales engineers may be high-risk AI

EU AI Act in practice, part 8: your European subsidiary uses AI to screen CVs. What is the deployer responsible for?

EU AI Act in practice, part 9: "we are not high-risk". What evidence does the Article 6(3) exception require?

EU AI Act in practice, part 10: the AI literacy obligation has been relaxed, not removed

Tell us what your EU customer is asking for.