Article 49 • EU database
EU AI Act registration obligations for U.S. providers
Article 49 links certain high-risk and classification decisions to registration in the EU database. For non-EU providers, the authorised representative can be part of the registration process where applicable.
Updated and legally reviewed: 26 September 2026.
Provider registration
Annex III systems and documented non-high-risk assessments can trigger registration.
Annex III high-risk systems
Before placing on the market or putting into service a high-risk AI system listed in Annex III, providers or, where applicable, authorised representatives must complete the Article 49 registration requirements, subject to the Regulation's specific categories and exceptions.
Article 6(3) non-high-risk conclusion
A provider that concludes an Annex III-listed system is not high-risk under the Article 6 filter must document that assessment and is subject to the registration obligation specified by Article 49(2).
Other actors
Certain public-authority deployers also have registration duties.
Article 49 includes registration obligations for public authorities, EU institutions and persons acting on their behalf when deploying relevant Annex III high-risk systems. Some sensitive categories use restricted/non-public database sections, and critical-infrastructure systems have specific national-level treatment.
For U.S. providers
Registration should be downstream of classification, not treated as a standalone filing product.
- Confirm EU AI Act territorial scope and provider role.
- Determine whether the system maps to Annex III.
- Apply Article 6 classification/filter analysis.
- Document the conclusion and identify the correct registration path.
- Confirm authorised-representative involvement where applicable.
- Maintain registration information as required when facts change.
Timeline
Registration must be mapped to the amended high-risk application timetable.
Regulation (EU) 2026/1744 moved the main Chapter III high-risk dates to 2 December 2027 for Article 6(2)/Annex III systems and 2 August 2028 for Article 6(1)/Annex I systems. Registration planning should follow the applicable legal provision and effective date, not an outdated August 2026 checklist.
Sources
Registration sources
Where an implementation page carries a Digital Omnibus disclaimer or pre-amendment text, the Official Journal/consolidated legal text controls.