Article 26 of the AI Act: what deployers of high-risk AI systems must do
Deployer checklist
- Confirm the system is high-risk (Article 6 and Annex III) and that you are a deployer, not a provider.
- Get the instructions for use from the provider and follow them.
- Name the people who oversee it and record their training.
- Set up monitoring and a route to report problems to the provider.
- Keep logs under your control for at least six months.
- Tell staff and their representatives before switching it on at work.
Common mistakes
- Assuming the vendor carries all duties. Deployers have their own list.
- Oversight by someone with no authority to stop or override the system.
- Deleting logs on a short default retention.
- Changing the intended purpose, which can make you a provider (Article 25).
Application dates: the AI Act sets 2 August 2026 for most high-risk rules (Article 113). In November 2025 the European Commission proposed changes to these dates in its Digital Omnibus package. Check the AI Act Service Desk for the date that applies to your system today.
Frequently asked questions
Who is a deployer under the AI Act?
A natural or legal person that uses an AI system under its authority, other than for personal non-professional activity.
How long must deployers keep high-risk AI logs?
At least six months, unless other EU or national law requires otherwise (Article 26(6)).
Must employers tell staff about high-risk AI at work?
Yes. Article 26(7) requires informing workers' representatives and affected workers before putting the system into use at the workplace.
Official sources
- EUR-Lex: Regulation (EU) 2024/1689 (AI Act)
- European Commission: AI Act Service Desk
- European Commission: AI Act policy page
Not legal advice. This is a free explainer of the AI Act text; dates and guidance can change, so check the official Commission pages or a qualified adviser. Last checked 25 Oct 2026.
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