Conformity Assessment (Article 43 EU AI Act)

Mandatory assessment for high-risk AI providers from 02 August 2026 (Digital Omnibus proposal 19 November 2025: postponement to 02 December 2027 - not adopted)

Practitioner's note: This article is practice-oriented compliance documentation, not legal advice. We are a compliance specialist, not a law firm. For legally binding information please consult a licensed lawyer.

TL;DR

Conformity assessment pursuant to Article 43 EU AI Act is the procedure for verifying whether a high-risk AI system meets the requirements of the Regulation. For most Annex III systems: internal conformity assessment (Article 43(2)). In special cases (Annex III No. 1 biometrics + specific subcategories): external assessment by a notified body.

What is Conformity Assessment (Article 43 EU AI Act)?

Two procedures are possible:

Application date 02 August 2026 legally binding (Digital Omnibus proposal 19 November 2025: postponement to 02 December 2027 - trilogue ongoing, not adopted). Result upon success: CE marking + EU database entry (Article 49).

Practical example

HR recruiting tool as a provider: - Prepare technical documentation per Annex IV - Implement risk management system (Article 9) - QMS manual (Article 17) - Document the internal assessment - EU declaration of conformity (Article 47) - EU database entry (Article 49) - Affix the CE marking

Frequently asked questions

Who designates the notified bodies?
Member States designate them to the EU Commission. As of 04/2026: Germany has 3 notified bodies for AI.
Can I, as an SME, perform an internal assessment?
Yes, Article 43(2) permits internal assessment for 90% of Annex III systems. However, you must have a QMS in place + full technical documentation.
What is the cost of an external assessment?
EUR 10,000-50,000 depending on system complexity. SME privilege under Article 62: reduced fees.

See also