Comply with the EU AI Act in 2 steps*!

If you are “a natural or legal person, public authority, agency or other body using an AI system under its authority except where the AI system is used in the course of a personal non-professional activity” and you are located in the EU,  in accordance with the provisions of Article 3.4) of the EU AI Act you are a “deployer” and therefore from 2 February 2025 you have to comply with two obligations:

1. Ensure, a sufficient level of AI literacy of your staff and other persons dealing with the operation and use of AI systems on your behalf, “taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used”. (Article 4 EU AI Act).
2. Ensure, that prohibited AI practices considered to be of unacceptable risk are not carried out in your organization, such as, -among others- subliminal manipulation, exploitation of social vulnerabilities, and other uses that may cause significant harm to individuals or groups. (Article 5 EU AI Act).

You also need to know that administrative sanctions have come into force from 2 August 2025, and as is set out in Article 99 (3) of the EU AI Act, the infringement of Article 5 may result in penalties up to EUR 35 000 000 €, or up to 7% of the total annual turnover of the offender, if it is a company.

If you are a deployer of AI systems, have you already ensured the compliance of these obligations?

* The information provided in this article is for general informational purposes only and does not constitute legal advice. For specific legal guidance, please contact us.

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