On 27 July 2026, EU AI Act Article 4 became an obligation of effort rather than result. You no longer have to guarantee anyone reaches a level. You do have to show you took considered measures, and there is no certificate that proves effort. The only thing that does is a record of your systems, your people, and the reasoning connecting them.
Amended by Regulation (EU) 2026/1744 · in force 27 July 2026
The amendment changed the standard, not the start date. The period before it is still a period you can be asked about
No size threshold, no risk carve-out, no high-risk gate
Chapter IX market surveillance applied from 2 August 2026. National authorities now hold their supervisory powers
Obligation of result
Obligation of effort
The amendment reads as relief and behaves as the opposite. An obligation of result can be discharged with a certificate. An obligation of effort cannot, because nothing certifies that a measure was considered.
What is left is the record: which groups you identified, what each was judged to need, why, and what you delivered against that judgement. The start date did not move. The period before the amendment is still a period you can be asked about.
Every AI tool in professional use, including the embedded, vendor-supplied and individually expensed AI most inventories never capture.
Who deals with each system, in what capacity: staff and, where they act on your behalf, contractors.
Why each group was given what it was given, and the dated evidence that it was delivered.
Supervision of Article 4 sits with national market surveillance authorities, and their powers reached AI systems on 2 August 2026.
They can open an investigation on their own initiative, with no complaint required. They can require documents, data and information in any form, on any medium, wherever it is stored, and take copies. They can carry out unannounced on-site inspections and enter any premises used for the business.
Article 4 is the one obligation where none of that matters, because there is nothing technical to inspect. There is one question, show us the measures you took, and whatever you produce is the answer. A blank is also an answer.
A structured, audit-ready system that turns “we did some training” into a defensible Article 4 record. Weeks, not months.
A standalone purchase: you do not need an ExecLevel AI platform subscription to buy it or to use it. For most organisations Article 4 is a days-long exercise with the right structure. Buying it starts with a free 30-minute call, and once you have bought it the register opens in your ExecLevel AI workspace.
Article 50 applies to you too? The Article 50 Readiness Pack includes everything in this register, plus the transparency disclosures, vendor clauses and evidence pack.
See the Article 50 Readiness PackIncludes:
ExecLevel AI was founded by Paul Parkinson, former Senior Business Consultant at IBM (USA, Europe and Asia) and Visiting Senior Fellow at Lincoln University Business School, drawing on AI agency leadership and AI audit practice, and a formal submission to the European Commission on this Regulation. The same governance discipline enterprises use, made accessible to AI providers and deployers.
We go through what you run, which duties reach it, and what is outstanding. No obligation, and you keep the findings either way.
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