EU AI Act technical documentation and dates for software teams

The EU AI Act: what software teams need to record.

If you build or substantially change a high-risk AI system, the EU AI Act requires technical documentation, logging, human oversight and evidence of accuracy, robustness and cybersecurity. Following the 2026 Digital Omnibus, the duties for high-risk systems listed in Annex III apply from 2 December 2027, and for those in regulated products from 2 August 2028.

Last reviewed 20 October 2026.

Key dates

DateWhat applies

2 August 2026Most transparency duties (Article 50)

2 December 2027Annex III high-risk systems

2 August 2028Annex I (regulated products)

Dates as amended by Regulation (EU) 2026/1744, the Digital Omnibus on AI, in force since 27 July 2026. Some duties, such as the ban on prohibited practices and the general-purpose AI rules, are unaffected and keep their original dates.

Does it apply to you?

It depends on what your system does and where it is used, not on how it was built. If you think a system may be high-risk, ask a legal adviser to classify it. We cannot do that for you.

What to document

Technical documentation for the system
Logging of what the system does
Human oversight arrangements
Evidence of accuracy, robustness and cybersecurity

How EmberNest helps

EmberNest keeps a record of every change, its approval, its tests and the model used. That is the engineering history these duties draw on.

What EmberNest does not do

EmberNest does not make a system compliant, and it does not classify a system for you.

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This page is not legal advice.

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