AI Act Classification & Scope Review – VoltLegal AI Act Classification & Scope Review - VoltLegal
EU AI Act · Product Classification

Your product uses AI. That does not tell you what the AI Act requires.

We determine whether your product and use cases are in scope, your legal role, the relevant classification, applicable duties and the current timeline — before uncertainty delays a customer deal or turns into unnecessary compliance work.

One product · Up to three AI use cases · Written classification and action plan

Your written answer
1
Is it an AI system?
Product, model and feature boundaries
2
Which use cases matter?
Intended purpose and affected decisions
3
What is your legal role?
Including rebranding and substantial modification
4
Which rules apply?
High-risk, transparency, GPAI or prohibited use
5
What must happen next?
Priority actions, dependencies and dates
Delivery within 5 working days
AI products SaaS integrations Third-party models White-label solutions EU market entry
When companies come to us

The legal question usually arrives through the business.

The trigger is rarely "we need an Article 6 analysis". It is a customer request, a product decision, a contract warranty or an investor question that the team cannot answer confidently.

"A customer sent us an AI questionnaire or contract addendum. How should we respond?"

We determine which statements your company can support and where the requested warranties go beyond your actual obligations.

"Can we confirm that our product is not high-risk?"

A conclusion is useful only if it is supported by the intended purpose, affected decisions, product design and written legal reasoning.

"We use an external model. What information do we need from its provider?"

Your position may depend on model documentation, technical information and contractual cooperation elsewhere in the AI value chain.

"Do our chatbot or generative features need notices or output marking?"

Article 50 can apply even where the product is not classified as high-risk.

"Could white-labelling, fine-tuning or changing the intended purpose change our role?"

Your company may assume provider responsibilities even though another business developed the underlying model or system.

"Which requirements must be built into the product — and which do not apply?"

Classification prevents unnecessary compliance work and expensive changes shortly before launch.

What a wrong assumption affects

Classification is not paperwork. It changes commercial and product decisions.

Customer deals

A customer may request an AI questionnaire, an AI Act warranty, human-oversight information or confirmation that the product is not high-risk.

Product roadmap

The answer determines whether the product needs AI notices, machine-readable marking, logging, human oversight or a high-risk compliance framework.

Compliance budget

Treating every AI feature as high-risk creates an oversized project. Treating every feature as low-risk can leave Article 50 or other duties unaddressed.

Contractual exposure

A broad compliance warranty or responsibility clause may make your company promise more than its actual role and available evidence support.

Vendor dependencies

Missing documentation from the external model provider can prevent you from substantiating your own customer-facing compliance position.

Launch timing

Classification determines what must happen now, what can be planned later and which product decisions should not wait for the high-risk deadlines.

Current timeline · July 2026

Digital Omnibus changed some dates — not the need to classify.

Already applicable

AI literacy measures, existing prohibited practices and GPAI-provider rules.

2 August 2026

Article 50 transparency duties, including notices and relevant content-marking requirements.

2 December 2027

High-risk obligations for standalone systems classified under Annex III.

2 August 2028

High-risk obligations for systems embedded in regulated products under Annex I.

Updated for the Digital Omnibus

The review applies the revised high-risk timetable, clarified safety-component rules, Article 50 transition where relevant, and available SME or small mid-cap simplifications.

The AI Act was not postponed as a whole.

The additional time is for implementing specific high-risk requirements. It does not remove the need to determine whether your product is high-risk, subject to Article 50, dependent on a GPAI provider or outside those regimes. Customer contracts, product architecture, vendor documentation and public compliance statements are being decided now.

The delay gives companies more time to implement high-risk requirements — not a reason to postpone classification.

Why misclassification matters

The consequences are not limited to a fine.

Authorities may require corrective action and may restrict use or sale, withdraw a system from the market or require a recall. In practice, unsupported customer statements and late product changes may become a problem earlier than enforcement.

Up to €35 million or 7%

of worldwide annual turnover for prohibited AI practices.

Up to €15 million or 3%

of worldwide annual turnover for specified operator obligations, including Article 50 transparency duties.

Up to €7.5 million or 1%

of worldwide annual turnover for incorrect, incomplete or misleading information supplied to authorities.

Maximum statutory amounts. Actual penalties must be proportionate and take account of the circumstances. For SMEs, including start-ups, the relevant ceiling is generally the lower of the fixed amount and turnover percentage.

AI Act Classification & Scope Review

A reasoned position your product, legal and commercial teams can use.

Use-case scoping

Separate analysis for up to three intended purposes.

Legal-role analysis

Provider, deployer and relevant value-chain changes.

Written classification

Conclusion and legal rationale for each use case.

Transparency check

Notices, marking and disclosure duties under Article 50.

Model dependencies

GPAI relevance and missing third-party information.

Action plan

Applicable dates, priority gaps and next steps.

Defined first step

One product · Up to three AI use cases

From€950

Delivered within 5 working days after receiving complete materials and holding the product workshop.

Start the review

Potential high-risk implementation, full technical documentation and company-wide AI governance are scoped separately.

A short, controlled process

Send what already exists. We identify what is missing.

1

Send materials

Product description, diagrams, model information, terms or customer questionnaires.

2

Product workshop

A focused session with the people who understand the intended use and implementation.

3

Receive the memo

Reasoned classification, obligations matrix and prioritised next steps.

Illustrative client scenario

One model. Three use cases. A customer asking for one compliance answer.

Why the company needed advice

A European SaaS company used the same external language model for document summarisation, drafting assistance and a customer-configured ranking feature. A prospective customer asked it to confirm its AI Act status and accept broad compliance warranties.

Why a single answer was unsafe

The internal team had treated the product as one AI system. That did not show whether the three features had the same intended purpose, whether Article 50 applied, whether the ranking function required a separate high-risk analysis or which information had to come from the model provider.

What the review delivered
  • A written classification and legal rationale for each use case
  • A legal-role analysis for the company and the external model provider
  • An Article 50 transparency assessment
  • A list of missing information to request from the model provider
  • Proposed wording for the customer questionnaire and contractual response
  • A prioritised roadmap of required and non-required measures
The practical result

The company had a documented position it could use with the customer, avoided giving a blanket warranty for the entire product and gave its product team a defined list of actions instead of starting an unnecessarily broad AI governance project.

This is a classification and scoping assessment, not an AI Act certification or a complete high-risk compliance audit. Any deeper work identified by the review is quoted separately.

Common questions

Before you decide whether the review fits.

Start with the product

Send the materials you already have.

We will confirm whether the review fits your situation, what is included, the fee and the delivery date before starting.

One step

Email your product materials

Opens your email app with the subject and questions already filled in. Attach whatever you already have and send.

Send product details  →

Useful materials include product descriptions, technical diagrams, model documentation, customer-facing materials, terms, AI questionnaires and existing legal analysis.

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