The consultation deadline has been extended to July 23, 2026. The guidelines address how both AI providers and deployers should assess whether their systems fall into the high-risk classification under the Act's risk-based framework, which designates systems as high-risk either because they are safety components in regulated products or because they operate in sensitive contexts affecting health, safety, or fundamental rights.
Attorneys should monitor this closely. The high-risk classification triggers substantial compliance obligations—including conformity assessments, documentation, and human oversight requirements—with compliance deadlines beginning December 2, 2027 for most standalone systems and August 2, 2028 for product-integrated systems. The Commission's interpretation of Article 6 will directly shape how companies across multiple sectors classify their AI systems and plan compliance. With transparency obligations already beginning in August 2026, firms have a narrow window to influence how these critical rules will be enforced.