AI Act for Education & EdTech: Which AI Systems Are High-Risk and What You Must Do

Under the EU AI Act (Regulation 2024/1689), the following AI applications in Education & EdTech are classified as high-risk and require full conformity assessment. Article 50 transparency obligations have applied since 2 August 2026; Annex III high-risk obligations apply from 2 December 2027 under the Digital Omnibus on AI (Regulation (EU) 2026/1744):

Student assessment, admissions scoring, learning analytics, proctoring, attention monitoring

These systems fall under Annex III category 3(a-c) education. Providers must implement risk management (Article 9), maintain technical documentation (Article 11), ensure data governance (Article 10), and enable human oversight (Article 14).

Transparency to students and parents. Bias testing for admissions AI. Human oversight of grading. Age-appropriate safeguards.

Providers (developers of AI systems) bear primary compliance responsibility: conformity assessment, CE marking, EU database registration, and post-market monitoring.

Deployers (companies using AI systems) must ensure human oversight, conduct Fundamental Rights Impact Assessments where required, and maintain usage logs.

AI Act Article 50 transparency obligations have applied since 2 August 2026. Annex III high-risk obligations apply from 2 December 2027 under the Digital Omnibus on AI (Regulation (EU) 2026/1744). No AI Act enforcement precedent currently exists. This page will be updated as enforcement cases emerge.

Penalties for non-compliance range up to EUR 35 million or 7% of global annual turnover for prohibited practices, and EUR 15 million or 3% for other violations.

• AI Act High-Risk Classification Guide
• Conformity Assessment: Step-by-Step
• Fines and Penalties Across EU
• August 2026 Deadline Checklist