Do we have to register our HR AI in the EU database?

What Trusq bases this on

These released rules are in Trusq and are read again with every publication; if a rule changes, this page changes with it.

• Registration as a public-authority deployer AI Act 26, AI Act 49, AI Act 71

Sources

1. [1] AI Act Art. 49(1) (AI Act, Regulation (EU) 2024/1689). The provider registers itself and its Annex III system (except point 2) in the EU database before it is placed on the market or put into service.

   Before placing on the market or putting into service a high-risk AI system listed in Annex III, with the exception of high-risk AI systems referred to in point 2 of Annex III, the provider or, where applicable, the authorised representative shall register themselves and their system in the EU database referred to in Article 71.

   Source, retrieved on 2 October 2026.
2. [2] AI Act Art. 49(2) (AI Act, Regulation (EU) 2024/1689). A provider that, under Article 6(3), does not consider its system to be high-risk also registers it.

   Before placing on the market or putting into service an AI system for which the provider has concluded that it is not high-risk according to Article 6(3), that provider or, where applicable, the authorised representative shall register themselves and that system in the EU database referred to in Article 71.

   Source, retrieved on 2 October 2026.
3. [3] AI Act Art. 49(3) (AI Act, Regulation (EU) 2024/1689). Deployers register only if they are public authorities or Union institutions, bodies, offices or agencies, or act on their behalf.

   Before putting into service or using a high-risk AI system listed in Annex III, with the exception of high-risk AI systems listed in point 2 of Annex III, deployers that are public authorities, Union institutions, bodies, offices or agencies or persons acting on their behalf shall register themselves, select the system and register its use in the EU database referred to in Article 71.

   Source, retrieved on 2 October 2026.
4. [4] AI Act Art. 26(8) (AI Act, Regulation (EU) 2024/1689). Only deployers that are public authorities or Union institutions, bodies, offices or agencies have the registration duties of Article 49.

   Deployers of high-risk AI systems that are public authorities, or Union institutions, bodies, offices or agencies shall comply with the registration obligations referred to in Article 49.

   Source, retrieved on 2 October 2026.
5. [5] Regulation (EU) 2026/1744 Art. 1(40)(b) (replaces AI Act Art. 113, third paragraph, point (c)) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). The high-risk rules (Chapter III, Sections 1 to 3) apply to Annex III systems from 2 December 2027.

   Chapter III, Sections 1, 2, and 3, with the exception of Article 6(5), shall apply from: (i) 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III; and

   Source, retrieved on 2 October 2026.
6. [6] AI Act Art. 25(1) (AI Act, Regulation (EU) 2024/1689). A deployer becomes the provider of a high-risk system if they put their name or trademark on it, substantially modify it so that it remains high-risk, or change the intended purpose of a system (including a general-purpose AI system) so that it becomes high-risk.

   Any distributor, importer, deployer or other third-party shall be considered to be a provider of a high-risk AI system for the purposes of this Regulation and shall be subject to the obligations of the provider under Article 16, in any of the following circumstances: (a) they put their name or trademark on a high-risk AI system already placed on the market or put into service, without prejudice to contractual arrangements stipulating that the obligations are otherwise allocated; (b) they make a substantial modification to a high-risk AI system that has already been placed on the market or has already been put into service in such a way that it remains a high-risk AI system pursuant to Article 6; (c) they modify the intended purpose of an AI system, including a general-purpose AI system, which has not been classified as high-risk and has already been placed on the market or put into service in such a way that the AI system concerned becomes a high-risk AI system in accordance with Article 6.

   Source, retrieved on 2 October 2026.
7. [7] AI Act Art. 3(3) (AI Act, Regulation (EU) 2024/1689). A provider is anyone who develops an AI system, or has one developed, and places it on the market or puts it into service under their own name or trademark.

   ‘provider’ means a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model or that has an AI system or a general-purpose AI model developed and places it on the market or puts the AI system into service under its own name or trademark, whether for payment or free of charge;

   Source, retrieved on 2 October 2026.