AI LAW RADAR · Daily Last verified 24 Jun 2026

Topic dossier

High-risk & high-impact AI obligations

How the major risk-based regimes define high-risk or high-impact AI, and the assessments, oversight and documentation that classification triggers. 7 obligations across 7 jurisdictions — 4 in force, 2 proposed. Next dated deadline: 1 Jan 2027.

Risk-tiering is the architecture of most comprehensive AI laws: a system classified as high-risk — or high-impact — attracts the heaviest duties, typically a pre-deployment assessment, human oversight, risk management, technical documentation and sometimes registration. The EU AI Act’s Annex III is the reference model; South Korea, Vietnam, Peru, Brazil and the DIFC each run their own variant. The obligations below are the high-risk tier of each regime.

The Register

7 obligations · 7 jurisdictions

European Union 1

EU Proposed

High-risk AI obligations (Annex III)

Binds Providers & deployers of Annex III high-risk AI (employment, credit, education, biometrics, law enforcement, migration). Omnibus defers this from 2 Aug 2026 to 2 Dec 2027: EU Parliament adopted 16 Jun 2026; Council adoption + OJ publication still pending, so the original date legally stands until then.

Pending — Digital Omnibus deferral (Parliament-adopted 16 Jun 2026; Council adoption + OJ publication still pending). The original 2 Aug 2026 date legally stands until publication.

Stated maximum penalty — Up to 3% turnover or €15M

Proposed · target 2 Dec 2027 checked 24 Jun 2026 EU AI Act (Digital Omnibus) ↗ low confidence

United States 1

US · CO Binding

Colorado AI Act (SB 26-189)

Binds Developers & deployers of automated decision-making tech in consequential decisions. ADMT documentation, consumer notice & appeal rights.

Stated maximum penalty — AG enforcement; per violation

Applies 1 Jan 2027 checked 21 Jun 2026 SB 26-189 ↗ high confidence

South Korea 1

S. Korea Comprehensive

AI Basic Act — high-impact AI duties

Binds Operators of high-impact AI and advanced / high-compute AI. Risk management, human oversight and impact assessment for high-impact / advanced AI (MSIT enforcement grace period through 2026).

MSIT is running an enforcement grace period through ~2026.

Stated maximum penalty — Admin fine up to ₩30M

In force · 22 Jan 2026 checked 24 Jun 2026 AI Basic Act ↗ medium confidence

Brazil 1

Brazil Proposed

AI Act bill (PL 2338/2023) advancing

Binds Would bind AI providers / deployers once enacted. Risk-based, EU-style framework; Senate-approved Dec 2024, now before the Chamber of Deputies.

Senate-approved Dec 2024; before the Chamber of Deputies.

Stated maximum penalty — Bill: up to R$50M / 2% revenue

Proposed checked 24 Jun 2026 PL 2338/2023 ↗ medium confidence

Vietnam 1

Vietnam Comprehensive

Law on AI — risk-tiered obligations

Binds AI developers / providers / deployers / users; extraterritorial (local representative required). Three-tier risk classification; high-risk AI needs conformity assessment + registration (general grace to 1 Mar 2027).

Grace period: general to 1 Mar 2027 (18 months for health, education and finance).

Stated maximum penalty — Admin fines up to ₫2B (decree-set)

In force · 1 Mar 2026 checked 24 Jun 2026 Law 134/2025/QH15 ↗ medium confidence

Peru 1

Peru Comprehensive

AI Law 31814 + Reglamento — risk-based regime

Binds Public and private AI developers / deployers. Prohibited / high-risk / acceptable tiers; high-risk AI needs prior evaluation, human oversight and transparency.

Stated maximum penalty — Referral to data-protection / Indecopi

In force · 22 Jan 2026 checked 24 Jun 2026 Ley 31814 + DS 115-2025-PCM ↗ high confidence

United Arab Emirates 1

UAE Binding

DIFC Data Protection Regulation 10

Binds Controllers / operators deploying autonomous or AI systems processing personal data in the DIFC. Binding rules for autonomous / AI systems processing personal data in the DIFC; high-risk needs certification or an Autonomous Systems Officer.

DIFC free-zone scope; enforcement from early 2026.

Stated maximum penalty — DIFC data-protection fines

In force · 1 Jan 2026 checked 24 Jun 2026 DIFC Regulation 10 ↗ medium confidence

Questions & answers

From the data

What is a high-risk AI system?

A system whose use could materially affect safety or fundamental rights — for example in employment, credit, essential services, biometrics or critical infrastructure. The EU AI Act lists these uses in Annex III; other regimes use comparable high-risk or high-impact categories with their own lists.

What does a high-risk classification require?

Usually a pre-deployment or conformity assessment, human oversight, risk management, technical documentation and sometimes registration. The precise package depends on the instrument — see each row’s primary source.

When do the EU AI Act’s high-risk rules apply?

The Annex III high-risk obligations were set for 2 August 2026. The Digital Omnibus, adopted by the European Parliament on 16 June 2026, proposes deferring them to 2 December 2027; until the Council adopts it and it is published in the Official Journal, the original date legally stands.

Which jurisdictions does AI Law Radar track for high-risk ai systems?

We currently track high-risk ai systems obligations across 7 jurisdictions: European Union, United States, South Korea, Brazil, Vietnam, Peru and United Arab Emirates. Each is dated and linked to its primary source on this page.