On 1 August 2024, the EU AI Act entered into force. Most of its provisions will apply from 2 August 2026. For organisations developing, deploying, or procuring AI systems for border management or identity verification, the implementation timeline is already underway. The Act is widely regarded as the world’s first comprehensive regulatory framework for artificial intelligence.
High-risk AI: what it means in practice
The EU AI Act classifies certain AI systems into risk categories. AI systems used for biometric identification, migration, asylum, border control management, and law enforcement are explicitly designated as high-risk in many operational contexts. This classification is significant because it triggers extensive regulatory obligations before such systems can be placed on the market or put into service.
What high-risk classification requires
High-risk AI systems are subject to requirements including: a documented risk management system; data governance and data quality measures designed to reduce bias and errors; technical documentation sufficient for conformity assessment and regulatory review; automatic logging capabilities to support traceability and post-hoc investigation; human oversight measures enabling operators to interpret, monitor, and override system outputs where appropriate; and defined standards for accuracy, robustness, and cybersecurity.
What this means for procurement
For border authorities procuring biometric systems, the Act creates substantial due diligence obligations. Procuring a system from a vendor unable to demonstrate conformity assessment and compliance documentation may create both operational and legal risk.
The EINSTEIN project has integrated EU AI Act compliance considerations into its development process from the outset, working with ethics and legal experts at Trilateral Research to help ensure that its applications are aligned with the requirements expected to apply at operational deployment.
© 2026 EINSTEIN Consortium. EINSTEIN is funded by the European Union’s Horizon Europe programme (GA No. 101121280) and by UKRI (IFS 10093453). Views expressed are those of the authors only. www.einstein-horizon.eu