The high-risk regime slipped to December 2027. The transparency obligations did not. If you're a company selling into the EU, the chatbot on your site and the AI content you generate are in scope right now.
30-second scope test Reserve your spot for an online callFour questions taken from Article 2 of the Regulation. Being established outside the EU does not put you out of scope on its own — what matters is where the output is used.
In an audit, or on an EU buyer's supplier form, what's asked for isn't a report — it's a completed file. The six documents delivered:
You can download the blank templates here for free. If you'd like help filling them in for your company, click here to arrange a preliminary call.
Scope is determined in the preliminary call; the fee is fixed and given in writing up front. No hourly billing.
These templates are the simplified form of documents we've actually used in compliance work at the intersection of the EU AI Act, GDPR and KVKK. Every clause has been filled in once for a real system and read once by the other side.
Part of it was. The Digital Omnibus moved the obligations for high-risk systems (Annex III) to 2 December 2027 and product-embedded systems to 2 August 2028. The transparency obligations in Article 50 stayed outside that postponement and apply as of 2 August 2026.
The Regulation applies even where the provider or deployer is established in a third country, as long as the system's output is used within the Union (Art. 2(1)(c)). Your servers can be in Istanbul and your office in Ankara; if you provide an assistant running on your German customer's website, you're in scope.
If you offer a third-party system under your own name or brand, make a substantial modification, or change its intended purpose, you're deemed a provider under Article 25. Most white-labelled AI products are in this situation and don't know it. It's the first thing we look at in the preliminary call.
An Article 50 breach is subject to administrative fines of up to EUR 15 million or 3% of worldwide annual turnover under Article 99, whichever is higher; for SMEs, whichever is lower. But in practice the fine doesn't come first: EU corporate buyers' supplier-audit forms ask for a compliance statement, and a supplier without one drops off the purchasing list.
Conformity assessment, technical documentation and CE marking for high-risk systems (Chapter III), together with the Chapter V obligations of general-purpose AI model providers, are out of scope. What's covered is the four paragraphs of Article 50. If yours is a broader matter, we say so in the preliminary call.
20 minutes. You share your screen, we look at your site and the tools you use together, and work out which paragraphs apply. By the end you know whether you're in scope and what's missing. Even if you decide not to run the work with us, that information stays with you.
Twenty minutes. If you're out of scope, we tell you that clearly too.
Reserve your spot for an online call You pick a suitable time from the calendar · the call is online