The EU AI Act: what small businesses should check
Roles, risk, transparency and AI Act application dates: a checklist for assessing AI systems used in a business.
The AI Act concerns providers and users of AI systems in the EU. For a small business, the starting point is an inventory of systems, purposes and data. This guide supports the technical assessment; legal classification depends on the particular use case.
Role and intended purpose
Using an API does not by itself establish whether you are a provider or deployer. Consider how you develop, distribute, modify and present the system. Substantial modifications or a different intended purpose can change responsibilities.
Risk and transparency
The Act includes prohibited practices, high-risk systems and specific transparency requirements. A “productivity” label does not establish a system’s classification: assess its actual use. Chatbots must make AI interaction clear where required. Recruitment and other sensitive applications need a specific assessment.
Application dates to check
- 2 February 2025: general provisions, AI literacy and initial prohibitions.
- 2 August 2025: governance and general-purpose model obligations.
- 2 August 2026: most rules, including transparency, apply.
- 2 December 2027: rules for high-risk systems under Annex III.
- 2 August 2028: rules for high-risk systems embedded in regulated products under Annex I.
Transitional provisions also apply: check the date for the particular system. Sources: European Commission, AI Act Service Desk.
A practical checklist
- Inventory tools, suppliers, owners and intended uses.
- Document data flows, access and human oversight.
- Review roles, risk and obligations with the person responsible for compliance.
- Train the people using the system.
- Check privacy information, contracts and personal-data safeguards: the AI Act does not replace the GDPR.
- Keep the assessment and revisit it when the use changes.