Sovereignty
The European regulation on AI: the AI Act
The EU AI Act is the first comprehensive legal framework for artificial intelligence anywhere in the world. It classifies AI systems by risk level and imposes proportionate obligations. Its provisions apply progressively, with key deadlines in 2026.
Risk levels
The four risk levels
Unacceptable risk
Prohibited (social scoring, manipulation and the like).
High risk
Heavy obligations: risk management, human oversight, logging, registration. It covers in particular the assessment of eligibility for essential public services and benefits (annex III).
Limited risk
Transparency obligation: tell users they are interacting with an AI, and label generated content. This is the case for a generic document assistant.
Minimal risk
No specific obligation (spam filters and so on).
Decision
The decision point for a local authority
An AI document assistant is generally limited risk. But if it is used to process citizens' case files (income support, housing, welfare payments), it can shift into high risk (annex III §5a).
Good practice: settle that use in writing in a usage charter, and either frame it or exclude it explicitly. We support you through that decision.
Obligations
Key obligations & deadlines
| AI literacy (training users) | art. 4 |
|---|---|
| Transparency: “AI-generated content” | art. 50 · 2026 |
| Documented human oversight | high-risk systems |
| Obligations for general-purpose AI models (GPAI) | borne by the model provider |
Benefits
What a sovereign AI brings
- Transparency banner and labelling of generated content
- Logging and human oversight made easier (logs and histories stay within the deployment's perimeter)
- Technical documentation of the system provided
- Usage charter designed with you to frame the risk level
Sources
Official sources
- Regulation (EU) 2024/1689 (AI Act): full text on EUR-Lex (new window)
The official text of the European regulation on artificial intelligence.
- Regulation (EU) 2026/1744 (Digital Omnibus on AI): text published in the Official Journal, on EUR-Lex (new window)
The amending regulation of 8 July 2026, published in the Official Journal on 24 July 2026 and in force since 27 July 2026: postponement of the high-risk obligations, and until 2 December 2026 for generative AI systems placed on the market before 2 August 2026 to comply with the marking required by Article 50(2).
- European Commission: regulatory framework for AI (new window)
An overview of the risk-based approach and of the application timetable.
- AI Act Explorer (Future of Life Institute) (new window)
Article-by-article navigation through the regulation.
Contact
Get ahead of the 2026 deadlines
See also GDPR compliance and digital sovereignty.
To validate
Responsibilities to validate
Documentation supports the controller and DPO for the actual processing. A public-interest task requires a legal basis in law and processing necessary for that task; it is not universal. A GDPR DPIA and an AI Act fundamental-rights impact assessment are distinct. Human oversight alone does not rule out high-risk classification.
Timeline and classification: 12 October 2026
The Commission lists 2 December 2027 for Annex III high-risk systems and 2 August 2028 for systems integrated into relevant Annex I products. These dates are set by Regulation (EU) 2026/1744 (the “Digital Omnibus on AI”), published in the Official Journal of the EU on 24 July 2026 and in force since 27 July 2026. The Article 50 transparency obligations have applied since 2 August 2026; providers of AI systems, including general-purpose AI systems, that generate synthetic audio, image, video or text content and were placed on the market before that date have until 2 December 2026 to comply with the content marking required by Article 50(2) (new Article 111(4) of the AI Act). Other duties, including AI literacy, have their own dates. Assess purpose, provider or deployer role, exceptions to prohibitions and Annex I and III criteria separately.
European Commission: AI Act (new window) · EUR-Lex: Regulation (EU) 2026/1744 (new window)