AIRiskAware
Reference · Updated 2026

What Is High-Risk AI?

Under the EU AI Act, high-risk AI refers to AI systems listed in Annex III of the regulation: systems used in areas where errors or biased outcomes could cause serious harm to individuals' health, safety, or fundamental rights. They require the most demanding compliance obligations under the Act.

Key distinction: A system is high-risk based on its use, not its technical architecture. A facial recognition model used for photo organisation is minimal-risk. The same model used for law enforcement identification is high-risk. Classification depends on context of deployment.

Annex III: the full high-risk list

1. Biometric identification

Real-time or post-remote biometric identification systems; biometric categorisation by sensitive characteristics; emotion recognition

2. Critical infrastructure

AI used in management and operation of road traffic, water, gas, heating, or electrical critical infrastructure

3. Education and training

AI determining access or admission to educational institutions; evaluating learning outcomes; assessing students; monitoring students during tests

4. Employment and HR

AI for recruitment, CV screening and filtering; decisions affecting promotion, termination, task allocation, and monitoring

5. Essential services access

AI used in creditworthiness assessment and credit scoring; life and health insurance risk assessment; emergency service routing

6. Law enforcement

Polygraphs and similar tools; risk assessment of individuals; predictive policing; analysis of evidence; crime analytics profiling

7. Migration, asylum, border control

Lie detection tools; risk assessment for entry; examination of applications for asylum or visa; border surveillance

8. Justice and democratic processes

AI assisting courts in researching, interpreting law, or applying it to facts; AI influencing elections or voting behaviour

Obligations for high-risk AI

Risk management system

Ongoing risk identification, analysis, and mitigation throughout the AI lifecycle.

Data governance

Training, validation, and testing data must meet quality criteria; bias assessment required.

Technical documentation

Comprehensive documentation of system design, development, and performance maintained.

Record-keeping

Automatic logging of operations where technically feasible, retained for minimum periods.

Transparency to deployers

Instructions for use provided; deployers informed of capabilities, limitations, and human oversight requirements.

Human oversight

Mechanisms enabling humans to monitor, intervene, override, and where necessary halt the system.

Accuracy, robustness, cybersecurity

Performance validation across defined metrics; resilience to attempts to alter outputs.

EU database registration

Registration in the publicly accessible EU AI database before placing on market (except for law enforcement).

Full EU AI Act overview Download readiness checklist