Article 71 creates a public EU database of high-risk AI systems and Article 49 says who has to put entries in it. The duty is easy to summarise and hard to satisfy on short notice, because several of the Annex VIII fields ask for documents most teams have not written yet.
Who registers, and when
Article 49(1) of Regulation (EU) 2024/1689 requires the provider, or its authorised representative, to register both itself and the system in the EU database before placing an Annex III high-risk system on the market or putting it into service. The timing word is the one that bites: registration is a precondition of placing on the market, not a follow-up task.
There are two carve-outs from that general rule. Annex III point 2 systems — AI used as a safety component in the management and operation of critical digital infrastructure, road traffic, and the supply of water, gas, heating and electricity — are registered at national level instead. And systems in the law enforcement, migration, asylum and border control areas of Annex III points 1, 6 and 7 go into a secure, non-public section of the database with a reduced field set, discussed below.
Nothing here is legal advice. Whether your system is an Annex III high-risk system at all, and whether you are its provider rather than its deployer, are the two determinations that decide everything on this page, and both are fact-specific. See the provider and deployer distinction and then take advice.
The date on which this becomes a live obligation has moved. Under the Regulation as adopted, the Chapter III obligations for Annex III systems — Article 49 among them — applied from 2 August 2026. Regulation (EU) 2026/1744, the Digital Omnibus on AI, was adopted on 8 July 2026, published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026, moving the application date for stand-alone Annex III high-risk systems to 2 December 2027. For AI embedded in the regulated products listed in Annex I, the date moved from 2 August 2027 to 2 August 2028.
What that amending Regulation does to the operation of the EU database itself — whether Article 71 or the registration mechanics in Article 49 were adjusted alongside the application date — is beyond what this page can confirm. Read Regulation (EU) 2026/1744 and the consolidated text of the AI Act on EUR-Lex before relying on any detail of it.
The database is established by Article 71 and operated by the Commission, which is the controller for it and is required to provide adequate technical and administrative support. The field labels and the submission mechanics of the live portal may differ in wording from the Annex; the Annex is the authoritative list of what must be supplied, so prepare against the Annex and adapt to the form.
The provider fields (Annex VIII Section A)
Annex VIII Section A is the list for a provider registering a high-risk system under Article 49(1). Grouped by how much work each one is:
- Identity, which you already have. Name, address and contact details of the provider; the same for anyone submitting on the provider’s behalf; the same for the authorised representative where there is one; the system’s trade name plus any additional unambiguous reference allowing it to be identified and traced.
- Description, which you have to write. A description of the intended purpose of the system and of the components and functions it supports, and a basic and concise description of the information the system uses — data and inputs — and of its operating logic. This is the field teams underestimate. It is public, it is short, and it has to be consistent with the Annex IV technical documentation and with the Article 13 instructions for use.
- Status. Whether the system is on the market or in service, no longer placed on the market or in service, or recalled. This field is why registration is a living record rather than a filing.
- Certificate details, where a notified body was involved. The type, number and expiry date of the certificate, the name or identification number of the notified body, and a scanned copy of the certificate.
- Geography. The Member States in which the system has been placed on the market, put into service or made available.
- Attachments. A copy of the EU declaration of conformity referred to in Article 47, and electronic instructions for use. The instructions are not supplied for the law enforcement, migration, asylum and border control areas of Annex III points 1, 6 and 7. A URL for further information is optional.
Read that list as a dependency graph rather than a form. Two entries — the declaration of conformity and the electronic instructions for use — are complete documents. If they do not exist, registration cannot be completed, and since registration precedes placing on the market, the launch date is set by the slowest of those documents rather than by the form.
Registering a system you decided is not high-risk
This is the part of Article 49 that surprises people. Article 6(3) allows a provider to conclude that an Annex III system is not high-risk, where it does not pose a significant risk of harm to health, safety or fundamental rights — because it performs a narrow procedural task, improves the result of a previously completed human activity, detects decision patterns without replacing or influencing human assessment, or performs a preparatory task. That conclusion is not a quiet internal decision. Article 49(2) requires the provider to register itself and the system in the database anyway, before placing it on the market.
The Section B field set is shorter than Section A but contains the two fields that make the entry meaningful: the condition or conditions under Article 6(3) relied on, and a short summary of the grounds on which the system is considered not to be high-risk. A provider must also document that assessment under Article 6(4) and produce it to national competent authorities on request. So the assessment is written down twice — once publicly, in a summary, and once in full, on demand. Writing the public summary first, and finding it hard to write, is a reliable signal that the derogation does not fit.
The deployer fields, if you are a public body
Article 49(3) puts a registration duty on deployers — but only on deployers that are public authorities, Union institutions, bodies, offices or agencies, or persons acting on their behalf. A private company deploying somebody else’s high-risk system does not register it. A ministry deploying the same system does.
Annex VIII Section C asks such a deployer for its own identity details, the identity of anyone submitting on its behalf, the URL of the provider’s existing entry for the system, a summary of the findings of the fundamental rights impact assessment conducted under Article 27, and, where applicable, a summary of the data protection impact assessment. The FRIA summary is the operative item: the registration duty is the mechanism that makes the Article 27 assessment visible rather than internal, and a public body that has not done a FRIA cannot complete its registration.
The non-public section
Article 71(4) makes the database publicly accessible, free of charge, user-friendly and machine-readable — with the exception of the section covering the law enforcement, migration, asylum and border control use cases, and registrations connected to real-world testing. Those entries live in a secure area accessible only to the Commission and to the relevant national authorities, and Article 49(4) narrows the fields: essentially the provider’s identity plus the Annex VIII items that are relevant, without the public description and instructions. Article 71(5) limits personal data in the database to what is strictly necessary for collecting and processing information in accordance with the Regulation.
The procedure
The registration itself takes minutes. Everything upstream of it does not. Work in this order:
- Fix the classification. Decide whether the system falls in Annex III at all, and if it does, whether you are relying on the Article 6(3) derogation. That decision picks Section A or Section B, and the two paths do not converge later.
- Confirm you are the provider. If you put your name or trademark on the system, or you substantially modify a high-risk system already on the market, or you change its intended purpose so that it becomes high-risk, Article 25 makes you the provider and the registration duty is yours.
- Finish the Annex IV technical documentation and the conformity assessment under Article 43, then draw up the Article 47 EU declaration of conformity. Registration needs the declaration as an attachment, so this is the long pole.
- Write the two public-facing texts: the intended-purpose and operating-logic description, and the electronic instructions for use under Article 13. Check them against the technical documentation line by line — a public description that contradicts the technical file is the cheapest possible finding for a market surveillance authority to make.
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Assemble the record. A single reviewed file keyed to the Annex VIII items, so that the submission is transcription rather than authorship:
# Annex VIII Section A — pre-submission record provider: { name, address, email, phone } submitter: { name, address, contact } # if not the provider authorised_rep: { name, address, contact } # if provider is non-EU system: trade_name: "..." unique_reference: "..." # traceable across versions intended_purpose: "..." # matches Annex IV doc components: "..." inputs_and_logic: "..." # basic and concise status: on_market | withdrawn | recalled certificate: { type, number, expiry, body_name, body_id, scan } # if any member_states: [ ... ] attachments: eu_declaration: ./doc/eu-declaration-of-conformity.pdf # Article 47 instructions: ./doc/instructions-for-use.pdf # Article 13 info_url: "https://..." # optional Submit before placing the system on the market or putting it into service, and record the entry URL. Deployers that are public bodies need that URL for their own Section C entry.
Put the status field on a change trigger. Withdrawal, recall and any substantial modification all have to be reflected, and a registration that still reads “on the market” for a product you retired is a defect that costs nothing to avoid and is trivially visible to anyone reading the public database.
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