The Deadline
August 2, 2026 — high-risk AI system requirements under Annex III come into force. Penalties up to €35M or 7% of global annual turnover for serious violations. Up to €15M or 3% for non-compliance with high-risk obligations.
CRM-Relevant High-Risk Categories
Hiring and recruitment algorithms. Credit scoring. Biometric identification. Essential services access. Educational assessment. If your CRM integrates AI for any of these, you’re in scope.
Required Practices
Conformity assessments. Lifecycle documentation. Robust risk management. Meaningful human oversight of automated decisions. Audit trails. Technical documentation. Post-market monitoring.
Practitioner Action
Map your AI-touching workflows against Annex III categories. If any qualify, engage legal immediately. The August 2 deadline isn’t aspirational. Start the conformity work now — six months is tight for real documentation and process build-out.