The first comprehensive AI law, and the one most likely to decide what a product team may ship. Its structure is worth knowing even if a lawyer will make the call, because the tier decides the cost of the feature.
The four tiers
Unacceptable risk, prohibited. Social scoring by public authorities, manipulative techniques that cause harm, exploiting vulnerability, untargeted scraping of facial images, and emotion recognition in workplaces and schools, with narrow exceptions. These cannot be done at any level of accuracy or consent.
High risk, permitted with obligations. A defined list rather than a judgement call, covering AI in employment and worker management, education and exam scoring, credit and essential services, biometrics, critical infrastructure, law enforcement, migration, justice, and safety components of regulated products.
The obligations are substantial. A risk management system across the lifecycle, data governance covering quality and bias, technical documentation, logging, transparency to deployers, human oversight designed in, and appropriate accuracy, robustness and cybersecurity. Plus conformity assessment before it goes to market.
Limited risk, transparency duties. Systems interacting with people, generating synthetic content, or recognising emotion. The core duty is disclosure. People must be told they are dealing with a machine, and generated content must be marked as such in machine readable form.
Minimal risk. Everything else, which is most software. No specific obligations, and the Act encourages voluntary codes.
General purpose models
Foundation model providers carry their own duties, covering technical documentation, information for downstream developers, a copyright policy and a summary of training data. Models presenting systemic risk carry more, including evaluation, adversarial testing and incident reporting.
For most product teams this matters as something to ask a vendor for rather than something to produce.
Provider or deployer
The distinction decides which duties are yours. A provider develops a system or has it developed and puts it on the market under their own name. A deployer uses one under their own authority.
The trap is assuming that building on somebody else's model makes you a deployer. If you assemble a high risk feature and offer it under your name, you are its provider, whoever trained the underlying model.
Working out where you are
Ask three questions in order. Does the feature do anything on the prohibited list. Does it fall in a listed high risk area, which is largely a question about the decision it affects rather than the technology. And does it interact with people or generate content, which brings the transparency duty whatever else applies.
Most features land in minimal risk with a disclosure obligation. The ones that do not are usually obvious once the list is read, and the answer is worth writing down with the reasoning, because that document is the beginning of the technical documentation the Act would want anyway.
Timing
The Act entered into force in 2024 and applies in stages, with prohibitions first, then general purpose model duties, then the high risk regime. Anyone relying on a specific date should confirm it rather than take it from here, because the phasing has moved and may move again.