Article 111: AI Systems Already Placed on the Market or put into Service and General-Purpose AI Models Already Placed on the Market

Summary of Article 111

  • Compliance Timeline for Large-Scale IT Systems: AI systems used in large-scale IT systems listed in Annex X, placed on the market before August 2, 2027, must comply with this Regulation by December 31, 2030.
  • Compliance for High-Risk AI Systems: High-risk AI systems placed before August 2, 2026, must comply with the Regulation if significantly modified, while those used by public authorities must comply by August 2, 2030.
  • Compliance for General-Purpose AI Models: Providers of general-purpose AI models placed on the market before August 2, 2025, must comply with the Regulation by August 2, 2027.

Compliance Timeline for Large-Scale IT Systems

1. Without prejudice to the application of Article 5 as referred to in Article 113(3), point (a), AI systems which are components of the large-scale IT systems established by the legal acts listed in Annex X that have been placed on the market or put into service before 2 August 2027 shall be brought into compliance with this Regulation by 31 December 2030. The requirements laid down in this Regulation shall be taken into account in the evaluation of each large-scale IT system established by the legal acts listed in Annex X to be undertaken as provided for in those legal acts and where those legal acts are replaced or amended.

Compliance for High-Risk AI Systems

2. Without prejudice to the application of Article 5 as referred to in Article 113(3), point (a), this Regulation shall apply to operators of high-risk AI systems, other than the systems referred to in paragraph 1 of this Article, that have been placed on the market or put into service before 2 August 2026, only if, as from that date, those systems are subject to significant changes in their designs. In any case, the providers and deployers of high-risk AI systems intended to be used by public authorities shall take the necessary steps to comply with the requirements and obligations of this Regulation by 2 August 2030.

Compliance for General-Purpose AI Models

3. Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027.

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About the author
Philip Mohr

Philip Mohr

Philip Mohr, a certified AIGP, is an AI governance consultant with over a decade of expertise in product management, data governance and privacy, leading initiatives at Addtrust (addtrust.com).

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