Procurement workflow surface
A procurement officer evaluating a vendor against EU AI Act can use this page to walk the operative articles + paragraphs the instrument touches, anchored to the primary source. Each row groups every coverage cell that names that article so the reader sees WHICH governance topic each clause speaks to. Use it as a checklist scaffold, not as legal advice (see charter §7.4).
National Security Carveouts in AI Regulation
Art. 2(3) explicitly excludes AI systems used exclusively for military, defence, or national-security purposes
Verbatim text:
“This Regulation does not apply to AI systems where and in so far as they are placed on the market, put into service, or used with or without modification exclusively for military, defence or national security purposes…”
Art. 5(1)(h) prohibition + Art. 26(10) post-hoc rules
Verbatim text:
“the use of 'real-time' remote biometric identification systems in publicly accessible spaces for the purposes of law enforcement, unless and in so far as such use is strictly necessary for…”
(a) AI in Elections
Art. 5 prohibitions (subliminal manipulation) + Annex III §8 (democratic processes / elections high-risk)
Verbatim text:
“the placing on the market, the putting into service or the use of an AI system that deploys subliminal techniques beyond a person's consciousness or purposefully manipulative or deceptive techniques…”
Art. 50(4) (disclosure obligation for deep fakes)
Verbatim text:
“Deployers of an AI system that generates or manipulates image, audio or video content constituting a deep fake, shall disclose that the content has been artificially generated or manipulated.”
Arts. 13, 50 (transparency obligations)
Verbatim text:
“Providers shall ensure that AI systems intended to interact directly with natural persons … are informed that they are interacting with an AI system.”
Art. 50(2) — provider machine-readable marking obligation; Art. 50(4) — deployer disclosure for deep fakes (distinct from the `deepfakes` topic which focuses on misuse-harms)
Verbatim text:
“Providers of AI systems generating synthetic audio, image, video or text shall ensure the outputs are marked in a machine-readable format and detectable as artificially generated or manipulated.”
Arts. 51-55 (general-purpose AI + systemic risk)
Verbatim text:
“A general-purpose AI model shall be classified as a general-purpose AI model with systemic risk if it meets any of the following conditions: (a) it has high impact capabilities…”
Art. 52 + Annex XIII (10²⁵ FLOP presumption)
Verbatim text:
“a general-purpose AI model shall be presumed to have high impact capabilities … when the cumulative amount of computation used for its training measured in floating point operations is greater than 10^25.”
Art. 53(2) + Recital 102/104 — explicit open-source GPAI exemption (with caveats for systemic-risk models)
Verbatim text:
“The obligations in paragraph 1, points (a) and (b), shall not apply to providers of AI models released under a free and open-source licence … unless they are general-purpose AI models with systemic risks.”
Recital 105; CDSM Directive provides primary copyright framework
Verbatim text:
“[providers of general-purpose AI models shall] draw up and make publicly available a sufficiently detailed summary about the content used for training of the general-purpose AI model…”
Art. 85 (right to lodge complaints)
Verbatim text:
“any natural or legal person … may lodge a complaint with the relevant market surveillance authority … [where] there are grounds to consider that there has been an infringement of this Regulation.”
Annex III §4 (high-risk: employment management)
Verbatim text:
“Employment, workers' management and access to self-employment: AI systems intended to be used for recruitment or selection, and to make decisions affecting terms, promotion, or termination…”
5(a) AI in Healthcare
Annex III §5(a) (high-risk: essential services) + MDR overlap
Verbatim text:
“AI systems intended to be used to evaluate the eligibility of natural persons for essential public assistance benefits and services, including healthcare services…”
Annex III §6 (high-risk: law enforcement)
Verbatim text:
“Law enforcement: AI systems intended to be used by or on behalf of law enforcement authorities to assess the risk of a natural person offending or re-offending, as polygraphs, or to profile…”
3(a) AI in Education
Annex III §3 (high-risk: educational access)
Verbatim text:
“Education and vocational training: AI systems intended to be used to determine access or admission or to assign natural persons to educational and vocational training institutions…”
Recitals 1-5 + EU competence framing; AI Office establishes EU capacity
Verbatim text:
“The purpose of this Regulation is to improve the functioning of the internal market and promote the uptake of human-centric and trustworthy artificial intelligence…”
(65) Catastrophic & Existential Risk
Art. 51 + Recital 32 — systemic risk overlaps with but does not fully cover catastrophic-risk framing
Verbatim text:
“'systemic risk' means a risk specific to the high-impact capabilities of general-purpose AI models … with significant impact on the Union market or on public health, safety, security, or fundamental rights…”
Arts. 26-29 deployer obligations apply to agent operators; Arts. 51-55 GPAI obligations capture the underlying model
Verbatim text:
“Deployers of high-risk AI systems shall take appropriate technical and organisational measures to ensure they use such systems in accordance with the instructions for use accompanying the systems…”
Environmental Impact of AI Training
Art. 95 voluntary codes of conduct include environmental sustainability; Recital 142 references energy efficiency reporting for GPAI
Verbatim text:
“Codes of conduct may cover … assessing and minimising the impact of AI systems on environmental sustainability, including as regards energy-efficient programming and techniques for design…”