Direct answer
What are a deployer’s obligations under Article 26?
You describe: Your organisation uses (or will use) a supplier’s high-risk AI system and you want to know your own duties as deployer. Likely role: deployer (you use the system).
This applies now
- Article 4: AI literacyApplicable
- Article 50: transparencyApplicable
Coming up
- Annex III: high-risk AIfrom 2 December 2027
Article 26 requires deployers of high-risk AI to, among other things: use the system according to its instructions, ensure human oversight by competent persons, control relevant input data, monitor operation, retain logs and inform workers. For the Annex III route these duties follow the 2 December 2027 date, but the preparation (register, role assignment, literacy) is today’s work.
Your first actions
- Classify the use case and document the outcome. Assess Article 5, Article 6 and Annex III in that order and document purpose, context and any Article 6(3) exception.
- Take role- and context-specific AI literacy measures. Determine for each role, system and context which combination of instruction, guidance, practice or training is appropriate.
- Implement the applicable disclosure, marking or label. First determine which paragraph of Article 50 applies, then implement the specific transparency measure.
Record this
- Article 6 and Annex III classification record
- AI literacy measures record
- Transparency implementation record
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
Full map for your situationFollow-up questions
Execution
Record the classification in an AI register
A classification without a register and ownership is not demonstrable. Embed AI guides classification, register and reassessment in a fixed approach.
See the Embed AI approach