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EU AI Act

EU AI Act Annex III High-Risk Classification

Determine whether your AI system falls under the 8 high-risk categories of Annex III (Articles 6(1)-(2)) or qualifies for narrow procedural derogations under Article 6(3).

Last updated: 15 March 2026

Do Annex III high risk classification & Article 6(3) derogation need to comply with EU AI Act?

Determine whether your AI system falls under the 8 high-risk categories of Annex III (Articles 6(1)-(2)) or qualifies for narrow procedural derogations under Article 6(3). If yes: Classified as High-Risk AI System (Annex III). If not: Minimal / Low Risk AI System (Outside Annex I…

  • Yes path: Classified as High-Risk AI System (Annex III)
  • No path: Minimal / Low Risk AI System (Outside Annex III)
  • Use the step-by-step decision tree below for your exact situation
Step 1

EU AI Act · Question 1

Is your AI system intended to be deployed in any of the 8 Annex III domains (biometrics, critical infrastructure, education/vocational, employment/HR, essential public/private services, law enforcement, migration, or justice)?

Annex III covers high-impact societal sectors. Most general B2B developer tools, internal marketing copywriters, and generic search engines are outside these 8 areas.

For informational purposes only. Consult qualified legal counsel before making compliance decisions.

Decision tree questions

  1. Is your AI system intended to be deployed in any of the 8 Annex III domains (biometrics, critical infrastructure, education/vocational, employment/HR, essential public/private services, law enforcement, migration, or justice)?

    Annex III covers high-impact societal sectors. Most general B2B developer tools, internal marketing copywriters, and generic search engines are outside these 8 areas.

    • Yes: Continue to: Does the system directly evaluate individuals (e.g. CV screening, worker monitoring, student admissions, or credit scoring)?
    • No: Minimal / Low Risk AI System (Outside Annex III)
  2. Does the system directly evaluate individuals (e.g. CV screening, worker monitoring, student admissions, or credit scoring)?

    Annex III points 3, 4, and 5 specifically target recruitment, employee evaluation, educational access, and creditworthiness.

    • Yes: Continue to: Does the system perform ONLY a narrow procedural task or preparatory work without posing significant risk of harm to safety or fundamental rights (Article 6(3))?
    • No: Continue to: Is the AI used as a safety component in critical infrastructure (water, gas, electricity, road traffic) or safety-critical machinery?
  3. Does the system perform ONLY a narrow procedural task or preparatory work without posing significant risk of harm to safety or fundamental rights (Article 6(3))?

    Article 6(3) provides a narrow exemption if the system only formats data, detects duplicates, or performs narrow preliminary tasks that do not materially influence the final human decision.

    • Yes: Exempt under Article 6(3) Procedural Derogation
    • No: Classified as High-Risk AI System (Annex III)
  4. Is the AI used as a safety component in critical infrastructure (water, gas, electricity, road traffic) or safety-critical machinery?

    Annex III point 2 covers safety components in the management and operation of critical digital and physical infrastructure.

    • Yes: Classified as High-Risk AI System (Critical Infrastructure)
    • No: Minimal / Low Risk AI System (Outside Annex III)