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ARTICLE · 09 JUNE 2026

What To Know About The European Commission’s Draft Guidelines On The Classification Of High-Risk AI Systems

Barnes & Thornburg LLP
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The European Commission’s Draft Guidelines are the Commission’s next step in issuing practical guidance to the statutory text of Article 6 of the AI Act.

European UnionTechnology
Kaitlyn E. Stone
Kaitlyn E. Stone
William M. Carlucci
William M. Carlucci
Bryan Castro
Bryan Castro
Michael C. Zogby
Michael C. Zogby
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Highlights

  • AI providers and deployers now have additional time to assess the categorization of their systems and the compliance deadlines have been postponed for high-risk AI systems.
  • High-risk systems are those that are:
    • Embedded in products regulated by the European Union’s (EU) legislation on product safety; or 
    • Capable of significantly affecting people’s health, safety, or fundamental rights. 
  • Providers are responsible for describing a clear and unambiguous “intended purpose” of an AI system to categorize high-risk systems.
  • Compliance deadlines for high-risk AI systems have been postponed: systems subject to product regulation must comply by August 2, 2028, and systems classified by use case must comply by December 2, 2027. The European Commission is collecting stakeholder feedback on the draft guidelines until June 23, 2026. 

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