From 2 December 2027, providers of high-risk AI systems under Annex III must register themselves and the system in the EU database before placing it on the market. The database is not open yet. What it will ask for is already fixed in the Act, and assembling it is where the work is.
A classification check and a complete Annex VIII dossier now, and the filing done for you once the database accepts registrations. Fixed fee.
They have moved once already, through the Digital Omnibus, so each one comes with its source.
One more rule matters for systems already on sale. Under Article 111(2), a system placed on the market before 2 December 2027 only comes under these obligations if its design changes significantly afterwards. If yours will not change, you may not need to register at all, and we will tell you so rather than sell you a dossier.
We check the system against the Annex III areas and the Article 6(3) conditions and tell you in writing whether it is high-risk, whether an exemption can be claimed, and what follows. If you rely on Article 6(3), we draft the assessment record that Article 6(4) requires.
Every item the database will ask for, drafted and checked against your declaration of conformity and instructions for use where they exist, with every gap listed: provider and representative details, trade name and reference, intended purpose, data inputs and operating logic, market status, Member States and certificates. Section B if you rely on Article 6(3), Section C if you are a public authority deploying the system.
With your mandate, we file the registration as the person submitting on your behalf, which Annex VIII provides for, and send you the confirmation. If the database turns out not to accept filings made on a provider's behalf, we refund €190 and walk you through filing it yourself.
If the Commission changes the required fields or publishes the database's technical specification before it opens, we bring your dossier into line before we file it, at no extra charge.
The price is per AI system and excludes VAT where it applies. You can enter a VAT ID at checkout.
Worth reading before you pay, so there is no argument afterwards.
Any of those can be quoted separately. Write to office@c9group.dev, or see our AI Act compliance work.
No one can. The EU database is not open and the Commission has published no launch date; its service desk said in July 2026 that it expects the third quarter of 2027. The obligation applies from 2 December 2027 for Annex III systems. Everything except pressing submit can be done now.
Because the dossier depends on work that takes time: the classification, the declaration of conformity, the instructions for use. Having it ready makes the filing a formality when the database opens rather than a project in the same quarter as everyone else's.
Possibly not. Under Article 111(2), a system placed on the market before 2 December 2027 is only caught if its design changes significantly afterwards. Systems intended for public authorities are the exception: they must comply by 2 August 2030 whatever happens. If the classification check shows you are outside, we tell you.
No. A provider established outside the EU must also appoint an authorised representative in the EU under Article 22, from the same date, and the representative's details are part of the registration. We prepare the dossier with them in it; the representative role itself is a separate mandate.
Yes. If you rely on Article 6(3) to treat an Annex III system as not high-risk, Article 49(2) still requires you to register it, with fewer fields (Annex VIII Section B), and Article 6(4) requires the assessment to be documented. The Digital Omnibus proposed dropping this; the final text kept it.
Public authorities and EU bodies that deploy Annex III systems register their use too, under Article 49(3), with a summary of the fundamental rights impact assessment. Choose "a public authority deploying the system" in the form.
Annex VIII expects that someone may submit on a provider's behalf, so we expect it to work. If the database is built without that option, we refund €190 of the fee and take you through filing it yourself, with the dossier ready to copy in.
Tell us about the system, then pay through Stripe. We reply within one business day with the questionnaire.
The guide explains what Article 49 requires, who registers what, the Annex VIII fields, and how the dates moved.