Under the EU AI Act, you are a provider if you build AI and offer it under your own name. You are a deployer if you use AI at work.
The first question is whether you are covered, in which role, and for which systems. The dates matter too. The EU moved the high-risk deadlines in a change that came into force on 27 July 2026. Older guidance may carry the old dates.
When the EU AI Act applies
- 2 February 2025EU Bans on certain AI practices apply.
- 27 July 2026EU A change to the Act comes into force and moves the high-risk dates.
- August 2026EU Transparency rules apply, such as telling people they are talking to a chatbot.
- 2 December 2027EU High-risk rules apply in listed areas, such as employment and education.
- 2 August 2028EU High-risk rules apply to AI built into products, such as lifts or toys.
AI use cases that can pose serious risks to health, safety or fundamental rights are classified as high-risk.
What to do if the EU AI Act covers your UK firm
- List the AI systems you build, sell or use at work.
- For each one, note whether it is offered in the EU, or whether its output is used there.
- Decide your role for each: provider if you offer it under your own name, deployer if you use it at work.
- Check every date you are given against the European Commission's timeline.
- If your AI uses personal data in the UK, check UK data protection law as well.
- If you bring in help, ask whether the person holds an AI governance qualification, such as the IAPP's AIGP.
The EU AI Act and UK firms: common questions
What applies to us right now?
If the EU AI Act covers you, its bans and transparency rules apply now. Certain AI practices have been banned in the EU since 2 February 2025. Since August 2026, people who use an AI chatbot must be told it is a machine. The first high-risk rules start on 2 December 2027.
Do we need ISO 42001 for the EU AI Act?
The EU AI Act does not ask for ISO 42001 by name. Under Article 40 of the EU AI Act, a high-risk system that meets EU-approved standards counts as meeting the rules they cover. Article 40 does not name ISO 42001. ISO 42001 can still give your AI governance a structure.
What applies to our AI in the UK itself?
In the UK, data protection law applies to your AI where it uses personal data. The UK's Data (Use and Access) Act 2025 changed the rules on automated decisions. Its data protection parts were in force by 19 June 2026. UK regulations also require the UK data protection regulator to write a code of practice on AI and automated decisions.
Sources
- European Commission, AI Act, checked 29 September 2026
- European Commission, AI Omnibus, checked 29 September 2026
- AI Act Service Desk, checked 29 September 2026
- AI Act Service Desk, checked 29 September 2026
- AI Act Service Desk, checked 29 September 2026
- ICO, checked 29 September 2026
- legislation.gov.uk, checked 29 September 2026