Check the activity and role before the checklist.
The Act can apply to providers placing AI on the EU market, EU deployers and some non-EU activities where outputs are used in the EU. Scope and exceptions require a factual review; a company's registered address alone does not settle the question.
For each use case, identify who supplies the system, who operates it and how the output is used. Keep those facts separate from the legal conclusion so a reviewer can test the reasoning and update it when the deployment changes.
Separate the questions that need different answers.
Consider whether the activity is in scope, whether a prohibited practice is involved, whether high-risk criteria apply and whether specific transparency duties are relevant. General-purpose model responsibilities form another part of the framework. Avoid treating these as a single severity score.
The useful output is a set of reasoned decisions and assigned questions. For example, an uncertain supplier role should remain an explicit action rather than being concealed behind an overall readiness percentage.
Use the current application dates.
The AI Act has phased application. The 2026 amendments changed important high-risk milestones. The official Article 113 text is the reference for the applicable provisions and exceptions.
- General application: 2 August 2026, subject to exceptions.
- Relevant Chapter III provisions for Annex III high-risk systems: 2 December 2027.
- Relevant Chapter III provisions for Annex I product-related high-risk systems: 2 August 2028.
- Earlier provisions and other applicable laws can already create responsibilities; the later high-risk dates are not a general pause on governance.
Turn the review into specific work.
Build an inventory with clear purposes and owners. Record the role and classification questions, identify missing supplier or technical evidence and assign people to resolve them. Define how approval conditions, oversight and changes will be managed after the first review.
Use this guide to prepare a better discussion with your legal, technical and operational advisers. EUAIC can support the records and workflow around that discussion; this general guide is not a legal determination or certification of a system. Keep the official sources and review date with the programme.