Do we need to register our AI system in the EU database?

This applies now

• For this situation, the preparation phase matters most right now.

Coming up

• Articles 43-49: conformity assessment, CE and registrationfrom 2 December 2027
• Annex III: high-risk AIfrom 2 December 2027

Providers of high-risk Annex III systems register themselves and their system before placing it on the market (Article 49); public deployers also register their use. Those relying on the Article 6(3) exception must register that assessment as well. The duty follows the high-risk timeline to 2 December 2027. This is the EU database; the Dutch algorithm register is a separate national arrangement for government.

Your first actions

1. 1Complete the conformity route before market placement. Select the correct assessment procedure, draw up the EU declaration of conformity, affix the CE marking and register in the EU database.
2. 2Classify 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.

Record this

• Conformity file
• Article 6 and Annex III classification record