The AI Act: deployer obligations
Most AI Act material describes provider obligations. A company that buys and runs a system is a deployer, with a different and shorter set.
Which articles apply to a deployer?
Five, and only some depend on risk classification. Article 4 on AI literacy applies regardless.
- Article 4: taking measures to support the development of AI literacy among staff, with regard to role and context. In force since 2 February 2025, as rewritten by Regulation (EU) 2026/1744 from 27 July 2026.
- Article 14: human oversight, including the ability to interrupt the system.
- Article 26: use according to the instructions, assign a competent person to oversee, monitor, and retain logs.
- Article 12: technical capability for automatic recording of events.
- Article 50: telling people they are dealing with an AI system. Applies from 2 August 2026.
What are the dates?
Some obligations already apply and some were deferred. The common mistake is waiting for the furthest date with things that have been required for a while.
- 2 February 2025: Article 5 prohibitions and Article 4 AI literacy.
- 27 July 2026: Regulation (EU) 2026/1744 rewrites Article 4 into a duty of effort and defers the high-risk deadlines.
- 2 August 2025: obligations for general-purpose AI models.
- 2 August 2026: the remainder of the regulation, including Article 50.
- 11 August 2026: the Polish act on artificial intelligence systems enters into force.
- 28 October 2026: KRiBSI, the Polish supervisory commission, may inspect and fine.
- 2 December 2027: Annex III high-risk obligations, including the Article 26 deployer duties, deferred by Regulation (EU) 2026/1744.
- 2 August 2028: Annex I high-risk systems.
What comes first?
A register of AI systems with an owner for each, a record of training with scope and date, and logs with a defined retention. Three things, none of which requires buying a tool.
The fourth is harder and usually missing: a record of who allowed an agent to take a specific outward action.
Can a tool make a company compliant?
No. No software, Gorgos included, makes a company compliant with the AI Act. Compliance is assessed for specific systems and processes, and the company carries it.
What a tool can do is produce the evidence you would have to find anyway: who oversees, on what basis an action was permitted, and what was recorded.
This is not legal advice. Article numbers and dates are given with sources so they can be checked.