EU AI Act

You are almost certainly already in scope.

The AI Act has no size threshold. It applies by role and by territory, and the moment people in your company use AI for work, your organisation is a deployer with obligations of its own. What those obligations are depends on what the AI decides — not on how large you are.

Talk to us about your positionDoes it apply to us?
Scope

Two questions decide it.

Neither of them is about your size.

First: what is your role?

Do people in your organisation use AI in the course of their work?

You are a deployer.

This is nearly every company, and it is the answer most organisations get wrong. Not building AI makes you not a provider. It does not put you outside the Act.

Do you place an AI system on the market, or put one into service under your own name?

You are a provider.

Substantially heavier obligations, and you can arrive here without intending to — see below.

Do you import, distribute, or sell a product with AI built into it?

You are also in scope.

Importers, distributors, product manufacturers and authorised representatives each carry their own duties.

Second: where does the output land?

  • Established in the EU — in scope.
  • Established outside the EU, but the output of the system is used in the EU — also in scope.

This is why the Act reaches suppliers who have never had an EU entity, and why where a system runs is a question your auditor will ask.

What sits outside

  • Purely personal, non-professional use by an individual.
  • Research, testing and development before a system is placed on the market.
  • Military, defence and national security purposes.
There is no exemption by size

Nothing in the Act works like the employee or turnover thresholds in other EU regulation. Small and medium enterprises get lighter ways to comply — simplified technical documentation, regulatory sandboxes, fines scaled to their size — not an exemption from complying.

Dates

What applies now, and what is coming.

Two of these dates moved in July 2026. The one that is already enforceable did not.

2 February 2025
In force
AI literacy — Article 4

Every provider and every deployer, at every risk level. Reasonable measures so the people who use AI understand what it can and cannot do.

2 February 2025
In force
Prohibited practices — Article 5

Everyone.

2 August 2025
In force
General-purpose AI models, governance, penalties

Model providers, and the enforcement machinery behind everything else.

2 August 2026
In force
Transparency — Article 50

Tell people when they are dealing with AI. Mark synthetic content. Enforceable now by national authorities, with fines to €15M or 3% of worldwide turnover.

2 December 2026
Ahead
Machine-readable marking of generated content

Grace period for generative systems already on the market before August 2026.

2 December 2027
Ahead
High-risk deployer obligations — Article 26, Annex III

Human oversight, monitoring, informing workers — and keeping the system's automatic logs for at least six months.

2 August 2028
Ahead
High-risk AI inside regulated products — Annex I

Machinery, medical devices, vehicles and the rest of the product safety regime.

The December 2027 and August 2028 dates were moved by the Digital Omnibus, Regulation (EU) 2026/1744, in force since 27 July 2026. The transparency obligations were not moved — a distinction a lot of published guidance still gets wrong.

High risk

In ordinary companies, most high-risk AI sits in HR.

High risk is defined by what the system decides about people, not by how advanced it is. These are the Annex III areas an ordinary business actually touches.

Employment and worker management

Screening applications, allocating tasks, monitoring performance, decisions on promotion or termination.

Access to essential services

Creditworthiness assessment, and risk pricing for life and health insurance.

Education and vocational training

Admission, assessment of learning outcomes, proctoring.

Biometrics

Remote identification, biometric categorisation, emotion recognition.

A manufacturer that lets an AI tool shortlist candidates is the deployer of a high-risk system. Very few of them know it.

Where it lands

What the Act asks for, and where it comes from.

The third column is the honest one. No platform makes an organisation compliant, and any vendor whose table has only two columns is selling you something.

The obligationWhat Tandevia records or enforcesWhat stays with you
AI literacyArticle 4A record of who uses which model, for what, and how often — so training can be aimed at the people and tasks that need it.Deciding what your staff need to understand, and actually teaching them.
Knowing what AI you haveThe precondition for all of itEvery request attributed to a person, team, application or agent, across commercial, open-weight and self-hosted models.Classifying each use against Annex III and deciding your risk tier.
Transparency to peopleArticle 50Which models an application may reach, so a customer-facing assistant cannot quietly be switched to an undeclared one.Writing the disclosure into the interfaces your customers actually see. This is a property of your front end, not of the layer beneath it.
Human oversightArticle 26(1)Approval gates in Workflow Studio, with the approver, the moment and the decision recorded against each run.Choosing which steps need a person, and giving that person real authority to refuse.
Keeping the logsArticle 26(6)A queryable record of every request, model, decision and cost, with configurable retention — including what was held back from a model, exportable as a document.Setting retention to at least six months, and reconciling that with your data-protection rules.
Monitoring operationArticle 26(5)Usage, cost and policy decisions per team and application, with alerts before a ceiling is reached.Acting on what the monitoring shows, and reporting serious incidents.
Using it as instructedArticle 26(1)An approved model catalogue per team. Unapproved models are unavailable rather than discouraged.Reading the provider's instructions for use and configuring to match.
Input data governanceArticle 26(4)Inspection before content leaves your network, and of content coming in from external sources before a model reads it — applied by policy.Deciding what may be sent at all, and to whom.

One thing to check against your own plan: Article 26(6) sets a floor of six months for a high-risk deployer's logs. On Tandevia that means Business or Enterprise retention — the Team plan keeps three months, which is below the floor.

Article 25

You can become a provider without deciding to.

Three routes turn a deployer into a provider. When any of them applies, the provider obligations in Article 16 become yours and the original supplier stops being the provider of that system.

1You put your name or trademark on a high-risk system that is already on the market.
2You make a substantial modification to a high-risk system.
3You change the intended purpose of a system so that it becomes high-risk.

The third is the one that catches ordinary companies. Building an automation that screens job applicants out of a general-purpose model is exactly that change of purpose — and it is a decision usually made by a team that has never read the Act.

Where this is enforced

The record has to come from somewhere.

AI GatewayThe inventory and the record: every request attributed, priced and checked, whichever model answered it.AI Gateway →Workflow StudioWhere human oversight stops being a policy sentence and becomes an approval gate with a name and a timestamp on it.Workflow Studio →SecurityHow the controls are built, what we are certified for, and what we deliberately do not claim.Security →
What this page is not

This is a map, not legal advice. Nothing here makes an organisation compliant, and no product can — classification, training, disclosure and accountability stay with you. Check your own position with your own counsel.

Reflects the law as at September 2026, including Regulation (EU) 2026/1744. The AI Act is still moving; this page is dated for that reason.

Start with the inventory. Everything else rests on it.

You cannot classify, evidence or train for AI use you cannot see — and that is true whichever obligations turn out to apply to you. It is also the part that takes longest, which is why the deferral to December 2027 is time to use rather than time to wait.

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