Art. 71 EU AI Act (Regulation (EU) 2024/1689) plus Annex VIII: high-risk AI must be registered before being placed on the market. The European Commission operates the register, which is publicly accessible (with protection for trade secrets).
What is the EU Model Register?
Mandatory registration content:
Identity of the provider
System designation and purpose
Annex III area
Member States in which it is placed on the market
Conformity assessment data
Practical example
A provider of an HR AI tool registers in the EU database before market launch; for Annex III systems, the high-risk obligations of Chapter III, Sections 1-3 apply from 2 December 2027 (Regulation (EU) 2026/1744 (Digital Omnibus AI), in force since 27 July 2026). Update in the event of substantial modifications.
Germany and Austria: Applies equally in Germany and Austria (Regulation (EU) 2024/1689) — the EU Model Register follows directly from the AI Act, without any national restructuring of provisions; the registration obligation is identical in wording across the EU.
Frequently asked questions
Is there a fine for failure to register?
Registration is a provider obligation (Art. 49 in conjunction with Art. 16(i) EU AI Act). Infringements fall under Art. 99(4): up to EUR 15 million or 3% of total worldwide annual turnover for the preceding financial year — whichever is higher. The lower range of EUR 7.5 million or 1% (Art. 99(5)) applies only to incorrect, incomplete or misleading information supplied to authorities; Art. 99 does not provide for a rate of 1.5%.
Practitioner note: This article is practice-oriented compliance documentation, not legal advice. We are compliance specialists, not a law firm. For legally binding advice, consult an admitted lawyer.