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08 · Annex III High-Risk Use Cases

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note

Annex III is the use-case track into high-risk classification (Article 6(2)). Under PE-CONS 30/26, Chapter III, Sections 1–3 obligations for this track apply from 2 December 2027, pending OJ publication. A listed system escapes high-risk only via an Art. 6(3) exception and if it does not profile individuals.

Annex III is the use-case track into high-risk classification (Article 6(2)). An AI system is high-risk if it falls under one of the 8 areas below — unless it qualifies for an Article 6(3) exception (narrow procedural task, improves a completed human activity, detects patterns without replacing judgment, or preparatory task) and does not profile individuals. The Commission may amend this list by delegated act.

The 8 areas are listed verbatim from the regulation, including the precise sub-points (a)–(e) that the high-level summaries in 06 · High-Risk Classification compress into single examples.

1. Biometrics

In so far as their use is permitted under relevant Union or national law:

  • (a) Remote biometric identification systems.
    • Excludes biometric verification whose sole purpose is to confirm a person is who they claim to be.
  • (b) Biometric categorisation according to sensitive or protected attributes/characteristics, based on inference of those attributes.
  • (c) Emotion recognition systems.

2. Critical infrastructure

AI systems intended to be used as safety components in the management and operation of:

  • critical digital infrastructure,
  • road traffic, or
  • the supply of water, gas, heating or electricity.

3. Education and vocational training

  • (a) Determining access/admission or assigning people to institutions at all levels.
  • (b) Evaluating learning outcomes, including when used to steer the learning process.
  • (c) Assessing the appropriate level of education a person will receive or can access.
  • (d) Monitoring and detecting prohibited behaviour of students during tests.

4. Employment, workers' management and access to self-employment

  • (a) Recruitment or selection — targeted job ads, filtering applications, evaluating candidates.
  • (b) Decisions affecting terms of work — promotion/termination, task allocation based on behaviour or traits, and monitoring/evaluating performance and behaviour.

5. Access to and enjoyment of essential private and public services and benefits

  • (a) Used by/for public authorities to evaluate eligibility for essential public assistance benefits and services (incl. healthcare), and to grant/reduce/revoke/reclaim them.
  • (b) Evaluating creditworthiness or establishing a credit scoreexcept AI used to detect financial fraud.
  • (c) Risk assessment and pricing for life and health insurance.
  • (d) Evaluating and classifying emergency calls, or dispatching/prioritising emergency first response (police, firefighters, medical aid) and patient triage.

6. Law enforcement

In so far as their use is permitted under relevant Union or national law:

  • (a) Assessing the risk of a person becoming a victim of crime.
  • (b) Polygraphs or similar tools.
  • (c) Evaluating the reliability of evidence during investigation/prosecution.
  • (d) Assessing the risk of offending or re-offending (not solely based on profiling per Art. 3(4) of Directive (EU) 2016/680), or assessing personality traits/characteristics or past criminal behaviour.
  • (e) Profiling of natural persons (per Art. 3(4) of Directive (EU) 2016/680) in the course of detection, investigation or prosecution.

7. Migration, asylum and border control management

In so far as their use is permitted under relevant Union or national law:

  • (a) Polygraphs or similar tools.
  • (b) Assessing a risk (security, irregular migration, or health) posed by a person intending to enter or who has entered a Member State.
  • (c) Assisting authorities in examining applications for asylum, visa or residence permits, and associated complaints, including reliability-of-evidence assessments.
  • (d) Detecting, recognising or identifying persons in the migration/asylum/border context — except verification of travel documents.

8. Administration of justice and democratic processes

  • (a) Assisting a judicial authority in researching/interpreting facts and law and applying law to facts (or similar use in alternative dispute resolution).
  • (b) Influencing the outcome of an election or referendum or voting behaviour — excludes tools not directly exposed to natural persons (e.g. admin/logistical campaign organisation).

Cross-references

TopicReference
Classification rules & Art. 6(3) exceptionsArt. 6 · 06 · High-Risk Classification
Provider obligations (risk mgmt, data, docs, oversight)Arts. 9–17
Conformity assessment (mostly self-assessment; biometrics → notified body)Arts. 43–49 · 07 · Conformity Assessment
EU database registrationArt. 71
Fundamental rights impact assessmentArt. 27
Annex I product-safety track09 · Annex I Products