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Art. 49 EU AI Act: registration in the EU database for providers

By Michel Venniker· · Aligned with the consolidated EU AI Act, including the 2026 Omnibus amendments.

Art. 49 requires providers of high-risk AI systems to register the system in the EU database before placing it on the market. The database serves both market surveillance and public accountability, letting citizens see which high-risk systems are in use.

Updated: June 2026

Introduction: public accountability through registration

Article 49 of the EU AI Act establishes the EU database for high-risk AI systems, a public-facing transparencytransparencyOpenness about the fact that AI is used and how it operates in general: disclosures, documentation, notices. Pairs with explainability, which addresses individual outcomes.Open full entry → instrument that allows regulators, researchers, and the public to see which high-risk AI systems are deployed in the EU market. Registration is primarily a providerproviderThe actor who develops an AI system (or has it developed) and places it on the market or into service under its own name — carrying manufacturer-style duties: design controls, documentation, conformity.Open full entry → obligation, but deployers have related verification and, in some cases, direct registration duties.

What is the EU database?

The EU AI database is a centrally managed, publicly accessible registry of high-risk AI systems. It is maintained by the EU AI Office and includes:

  • Provider identification and contact information
  • The AI systemAI systemA machine-based system that, for explicit or implicit objectives, infers from input how to generate outputs — predictions, content, recommendations or decisions — that can influence physical or virtual environments. The OECD-style definition followed by the EU AI Act.Open full entry →'s name and version
  • The Annex IIIAnnex IIIThe EU AI Act's list of high-risk use-case areas — biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration, justice.Open full entry → classification category
  • Intended purpose and deployment context
  • Countries of deployment within the EU
  • Link to the EU declaration of conformity
  • Post-market monitoringpost-market monitoringProvider-side duty to systematically collect and act on experience from systems in use — the product-regulation half of continuous monitoring.Open full entry → plan summary

The database has a public section (accessible to all) and a restricted section (accessible to market surveillance authorities only, containing confidential technical information).

Provider registration obligations under Art. 49

Art. 49.1 requires providers to register their high-risk AI systems before placing them on the EU market. Key requirements:

  • Registration must occur prior to market placement, not after
  • Each new version of a high-risk AI system requires a new or updated registration
  • Providers outside the EU must designate an EU authorised representative to handle registration
  • Registration generates a unique system identifier that must appear on the EU declaration of conformity

Deployer verification and due diligence

For deployers, Art. 49 creates an important due diligence obligation: verify that your high-risk AI provider has fulfilled registration obligations. Steps:

  1. Request the EU database registration number from your provider
  2. Cross-check the number against the public EU database once operational
  3. If the provider cannot provide a registration number, this is a red flag requiring further investigation before deployment
  4. Document your verification process

Compliance checklist

  1. Have you requested EU database registration numbers from all high-risk AI providers?
  2. Have you verified these numbers against the public database?
  3. If you are a deployerdeployerAn organization using an AI system under its own authority in its activities — carrying operator duties: use per instructions, oversight, input relevance, monitoring, notices.Open full entry → with provider-equivalent obligations (provider outside EU): have you registered?
  4. Are registration numbers retained in your AI system inventory?
Legal referencesArt. 49

More on Transparency & explainability

Art. 12 EU AI Act: record-keeping and logging for high-risk AI

Reference

Art. 12 requires high-risk AI systems to technically allow for the automatic recording of events (logs) over their lifetime. The logging must enable traceability of the system's functioning at a level appropriate to its intended purpose, support post-market monitoring, and help identify situations that may lead to risk or substantial modification. It is a design obligation on the provider that makes the system auditable by construction.

Art. 26.7 EU AI Act: transparency obligations towards individuals

Reference

Art. 26.7 requires deployers of high-risk AI to inform the people who are subject to the system's decisions that a high-risk AI system is being used. This applies even where there is no direct interaction, such as CV screening or credit scoring.

Art. 26.8 EU AI Act: registration in the EU database

Reference

Art. 26.8 requires deployers that are public authorities (or act on their behalf) to verify that a high-risk AI system is registered in the EU database before putting it into use, and to refrain from using it if it is not.

AI in recruitment: risks, bias and what the EU AI Act already requires

Analysis

AI recruitment systems fall under Annex III of the EU AI Act as high-risk, which triggers the full deployer obligations of Article 26, human oversight, data quality, monitoring, log retention, and a Fundamental Rights Impact Assessment under Article 27. These duties cannot be transferred to the software vendor.

More on Accountability

Art. 10 EU AI Act: data and data governance for high-risk AI

Reference

Art. 10 requires that the training, validation, and testing data for high-risk AI systems meets quality criteria: relevant, sufficiently representative, and as free of errors and complete as possible for the intended purpose. It also requires documented data governance practices covering collection, preparation, bias examination, and gap mitigation, and it permits the limited processing of special-category data where strictly necessary to detect and correct bias, under safeguards.

Art. 12 EU AI Act: record-keeping and logging for high-risk AI

Reference

Art. 12 requires high-risk AI systems to technically allow for the automatic recording of events (logs) over their lifetime. The logging must enable traceability of the system's functioning at a level appropriate to its intended purpose, support post-market monitoring, and help identify situations that may lead to risk or substantial modification. It is a design obligation on the provider that makes the system auditable by construction.

Art. 19 EU AI Act: keeping the automatically generated logs

Reference

Art. 19 requires providers of high-risk AI systems to keep the logs that the system automatically generates (under Art. 12) for as long as they control them, for a period appropriate to the intended purpose and at least six months unless other law requires longer. It is the retention counterpart to the Art. 12 logging capability, and it works alongside the deployer retention duty in Art. 26.6.

Art. 26.1 EU AI Act: following provider instructions as a deployer

Reference

Art. 26.1 requires deployers to use high-risk AI systems strictly in accordance with the provider's instructions for use. This means using the system only for its intended purpose, within its specified technical configuration, and by qualified users, and documenting that compliance. Deviating from the instructions can shift liability entirely to the deployer.