Article 49: EU Database Registration
Article 49 requires providers and, in certain cases, deployers to register high-risk AI systems listed in Annex III in the EU database before placing them on the market or putting them into service. Registration uses structured information set out in Annex VIII. The database is managed by the Commission and serves both transparency (public access to certain fields) and market surveillance purposes. Providers must update entries for substantial modifications.
Who does this apply to?
- -Providers of high-risk Annex III systems before placing on the market or putting into service
- -Deployers when they are subject to registration under Article 49(3)
Scenarios
A vendor launches an Annex III employment tool without filing registration entries.
A deployer runs real-world testing outside a sandbox and must register under Article 60 pathway.
Provider registration (Article 49(1))
Providers must register themselves and their Annex III high-risk systems before placing on the market or putting into service. The entry must include elements laid down in Annex VIII Section A.
Systems also covered as regulated products (Article 49(2))
Where a Union harmonisation instrument already requires registration in another database, providers may use a simplified registration in the EU database referencing the existing entry—when implemented in Commission templates.
Deployer registration (Article 49(3))
Deployers of Annex III systems must register when they deploy an AI system that is not registered by its provider (for example certain public-sector deployments). Use Annex VIII Section C information.
Compliance checklist
- Identify who registers each system (provider vs deployer) using Article 49 tests.
- Prepare Annex VIII data fields in advance of release gates.
- Integrate registration IDs into procurement and IT asset inventories.
- Update entries for substantial modifications.
- Align registration timelines with FRIA notifications where both apply.
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Related annexes
- Annex VIII — Registration information
- Annex IX — Real-world testing registration
Frequently asked questions
Is registration public?
Certain information is publicly accessible to promote transparency; other fields remain accessible only to authorities—follow Commission UX and field guidance when published.
Do deployers also need to register high-risk AI systems in the EU database?
Yes for certain deployers. Article 49(3) requires deployers that are public authorities or EU institutions, and private deployers using systems listed in Annex III points 1(a), 6(a), and 7, to register the use of the high-risk AI system in the EU database before putting it into service.
Is the EU database publicly accessible?
Partially. Article 49(4) specifies that the information in Section A of Annex VIII (provider data) is publicly accessible. Section B (deployer data relating to law enforcement, migration, border control, and asylum) is accessible only to the Commission and market surveillance authorities for accountability reasons.