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title: "Ireland — Global AI Monitor"
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source_html: /jurisdictions/ireland/index.html
description: "Ireland AI governance record: 9 instruments, 9 obligations and 92 evidenced claims across 12 modules. Research as of 12 Nov 2026."
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# Ireland AI Regulation & Governance

12 active modules 0 quiet

Last updated 11 Nov 2026 · 12 modules · 9 instruments · 92 claims · 71 sources in the cumulative register

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Framework status Digital Omnibus on AI (Regulation (EU) 2026/1744) (Valid from 2026-07-27).

Main regulator Regulator [AI Office of Ireland (national coordinating office) under the Department of Enterprise, Tourism and Employment; 15 designated national competent authorities](https://enterprise.gov.ie/en/what-we-do/innovation-research-development/artificial-intelligence/eu-ai-act/)

Next milestone 2 Dec 2026 : New Art 5(1)(ba)/(bb) prohibitions apply ([02 Prohibited Practices](#sec-mod-prohibited_practices))

Record status Live · Periodic active record · 71 sources (67 retrieved) · 17 under review · Not yet expert-reviewed

✦ AI-assembled from cited sources

Evidence-gated · [How we verify](/methodology/#ai-content-disclosure) · Disclosure Not yet expert-reviewed · Not legal, compliance or investment advice. Facts are machine-assembled from cited public sources. Individual claims have not each been independently verified by a human reviewer. See [methodology](/methodology/).

Source tiers: T1 enacted statute, regulation, or binding supervisory order · T2 official regulator guidance, consultation, or registry · T3 international standard-setter or peer-reviewed analysis · T4 practitioner commentary or secondary reporting. Confidence: high = corroborated by retrieved T1/T2 text · medium = single official source or secondary corroboration · low = preliminary or unverified. [Full definitions →](/methodology/#source-tiers)

Research checked 12 Nov 2026 · Updated 11 Nov 2026 Record history Research as of 12 Nov 2026 · Record last changed 11 Nov 2026 · Published 11 Nov 2026 · Page built 12 Nov 2026

9 Instruments

9 Current instruments

2 Binding, in force +7 more binding, in-force date not recorded

9 Obligations

92 Claims

2 Upcoming milestones

71 Sources

## Next milestones in this record

- 2 Dec 2026New Art 5(1)(ba)/(bb) prohibitions apply Scheduled · [02 Prohibited Practices](#sec-mod-prohibited_practices)
- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) Scheduled · [01 AI Framework Law](#sec-mod-ai_framework_law)
- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) Scheduled · [07 Sectoral & Public-Sector AI](#sec-mod-sectoral_and_public_sector_ai)
- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) Scheduled · [08 Safety & Incident Reporting](#sec-mod-safety_and_incident_reporting)
- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) Scheduled · [10 Authorities & Enforcement](#sec-mod-authorities_and_enforcement)

Jump to module (12)

### 01AI Framework LawActive Derived: Probable▾#

Digital Omnibus on AI (Regulation (EU) 2026/1744) (Valid from 2026-07-27).

5 instruments (5 current) · 0 obligations · 22 claims · 1 milestone · Next: 2 Aug 2027 (EU-level AI regulatory sandbox operational deadline (deferred))

Ireland's AI framework rests on two layers of binding law currently in force. Regulation (EU) 2024/1689 (the EU AI Act) applies directly in Ireland as an EU Regulation, with effect from 1 August 2024, and follows a staggered application calendar: the Article 5 prohibited-practice provisions applied from 2 February 2025; Chapter III Section 4, Chapter V, Chapter VII, Chapter XII and Article 78 applied from 2 August 2025; and the Regulation applies generally from 2 August 2026. The Act's scope covers providers, deployers, importers, distributors and product manufacturers of AI systems with an EU nexus, subject to exemptions for military and defence use, national security, scientific research and development, open-source models (subject to exceptions), and purely personal non-professional use.

Regulation (EU) 2026/1744 (the Digital Omnibus on AI), in force from 27 July 2026, amends the AI Act's commencement schedule and literacy duty. It defers high-risk system obligations under Chapter III Sections 1-3 for Annex III use-case systems from 2 August 2026 to 2 December 2027, and defers Annex I product-safety route obligations to 2 August 2028. It also rewords the AI-literacy duty on providers and deployers from a duty to 'ensure' sufficient staff AI literacy to a duty to 'take measures to support the development of' it, not requiring any guaranteed individual level, effective from 27 July 2026.

At domestic level, the Regulation of Artificial Intelligence Act 2026 (No. 31/2026) was signed into law on 21 July 2026 and its main provisions came into operation on 31 July 2026, commenced by the Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026. The Act establishes the AI Office of Ireland as a body corporate and as Ireland's single point of contact under Article 70(2) of the AI Act; the Office became operational on 1 August 2026, superseding the interim ministerial designation, and the Act gives it statutory functions to coordinate competent authorities, raise AI literacy, and advise the Minister, acting independently. Article 70 of the AI Act separately requires Ireland to designate at least one notifying authority and at least one market surveillance authority; the Central Bank of Ireland is designated under Article 74(6) as market surveillance authority for high-risk AI systems used by financial institutions, and the Data Protection Commission is designated under Article 74(8) for high-risk AI systems in law enforcement, migration, justice and specified biometric uses under Annex III.

A Bill initiated in the Dáil on 4 February 2026 would extend Ireland's Harassment, Harmful Communications and Related Offences Act 2020 (Coco's Law) to intimate images generated or modified by computer graphics, including AI-generated deepfakes; it has not yet been enacted.

Read full sub-brief · 432 words

Instruments (5)
- Digital Omnibus on AI (Regulation (EU) 2026/1744) Valid from 2026-07-27Binding
- EU AI Act (Regulation (EU) 2024/1689) Valid from 2024-08-01Binding
- Regulation of Artificial Intelligence Act 2026 Valid from 2026-07-31Binding
- Regulation of Artificial Intelligence Act 2026 In force since 2026-07-31Binding
- Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 Valid from 2026-07-31Binding

Milestones

- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) UpcomingRegulation of Artificial Intelligence Act 2026

Claims and evidence (22)
- Article 70 of the AI Act requires Ireland to establish or designate at least one notifying authority and at least one market surveillance authority.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulations.ai](https://regulations.ai/eu-ai-act/ireland) T3 · Retrieved · retrieved 1 Nov 2026 · Art 73(1)Article 70 of the AI Act requires each EU Member State to establish or designate at least one notifying authority and at least one market surveillance authority

- S.I. No. 366 of 2025 designates the Data Protection Commission as the market surveillance authority for the purposes of Article 74(8) of the AI Act.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/2025/si/366/made/en) T1 · Retrieved · retrieved 1 Nov 2026 · Art 73The Data Protection Commission is designated as the market surveillance authority for the purposes of Article 74(8).

- The Regulation of Artificial Intelligence Act 2026 establishes the AI Office of Ireland as a body corporate and the single point of contact under Article 70(2) of the AI Act, commenced 31 July 2026.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/isbc/2026_31.html) T1 · Retrieved · retrieved 1 Nov 2026 · Art 79Ss. 1-77 | 31 July 2026 | Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2

- The AI Act applies to providers, deployers, importers, distributors and product manufacturers of AI systems with EU nexus, with exemptions for military/defence, national security, scientific R&D, open-source models (subject to exceptions), and purely personal non-professional use.Confidence: Confirmed · EvidencedEvidence and sources[Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/what-we-do/innovation-research-development/artificial-intelligence/eu-ai-act/) T1 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 366 of 2025it provides exemptions for certain applications of AI relating to national defence; national security; scientific R&D; R&D for AI systems, models; open-sourced models; and personal use.

- The AI Act applies generally from 2 August 2026, with Chapters I-II/Art 5 prohibitions from 2 February 2025 and Chapter III Section 4, Chapter V, Chapter VII, Chapter XII and Art 78 from 2 August 2025.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[ai-act-law.eu](https://ai-act-law.eu/article/113/) T3 · Retrieved · retrieved 10 Nov 2026Articles 102 to 110 shall apply from 27 July 2026.

- The Digital Omnibus on AI deferred Chapter III Sections 1-3 high-risk obligations for Annex III use-case systems from 2 August 2026 to 2 December 2027.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[ISMS Copilot](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 1 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027 (Annex III) and 2 August 2028 (Annex I product route).

- Providers and deployers must take measures to support development of sufficient AI literacy among staff; the Digital Omnibus on AI reworded this from a duty to 'ensure' to a duty to 'take measures to support the development of', effective 27 July 2026, not requiring any guaranteed individual level.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff

- Ireland must designate at least one notifying authority and one market-surveillance authority under Art 70 of the AI Act.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulations.ai](https://regulations.ai/eu-ai-act/ireland) T3 · Retrieved · retrieved 1 Nov 2026 · Art 73(1)Article 70 of the AI Act requires each EU Member State to establish or designate at least one notifying authority and at least one market surveillance authority

- Ireland's Regulation of Artificial Intelligence Act 2026 entered into force 31 July 2026, establishing the AI Office of Ireland, a sandbox, and an enforcement regime.Confidence: Probable · As of 31 Jul 2026 · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/isbc/2026_31.html) T1 · Retrieved · retrieved 1 Nov 2026 · Art 79Ss. 1-77 | 31 July 2026 | Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2
- [Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order
- [Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/legislation/si-no-403-of-2026.html) T1 · Retrieved · retrieved 1 Nov 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

- The AI Act's scope covers providers, deployers, importers, distributors and manufacturers, with exemptions for defence, R&D, open-source, and purely personal use.Confidence: Confirmed · EvidencedEvidence and sources[Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/what-we-do/innovation-research-development/artificial-intelligence/eu-ai-act/) T1 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 366 of 2025it provides exemptions for certain applications of AI relating to national defence; national security; scientific R&D; R&D for AI systems, models; open-sourced models; and personal use.

- The AI Act's application is staggered by chapter, fully applying from 2 August 2026 with earlier tranches from 2 February 2025 and 2 August 2025.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[ai-act-law.eu](https://ai-act-law.eu/article/113/) T3 · Retrieved · retrieved 10 Nov 2026Articles 102 to 110 shall apply from 27 July 2026.

- Providers and deployers must take measures to support AI literacy among relevant staff, under a duty softened by the Digital Omnibus on AI.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff
- [Praxikon](https://www.praxikon.com/en/ai-geletterdheid) T3 · Retrieved · retrieved 1 Nov 2026What changed in Article 4 on 27 July 2026? Regulation (EU) 2026/1744, the Digital Omnibus on AI, rewrote Article 4.

- Derived: Probable The Regulation of Artificial Intelligence Act 2026 (No. 31/2026) commenced on 31 July 2026, establishing the AI Office of Ireland, a single point of contact function, an AI regulatory sandbox and a domestic enforcement/penalty regime.Confidence: Probable · As of 31 Jul 2026 · EvidencedEvidence and sources[artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff
- [European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act-explorer) T1 · Retrieved · retrieved 1 Nov 2026 · s.1Article 22: Authorised representatives of providers of high-risk AI systems
- [European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99) T1 · Retrieved · retrieved 1 Nov 2026 · s.136Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to EUR 35 000 000
- [artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 403 of 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

- Derived: Probable The EU AI Act applies on a staggered calendar, with prohibitions in force since 2 February 2025, GPAI/governance/penalties provisions since 2 August 2025, and general application since 2 August 2026.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113not later than 15 days after the provider or, where applicable, the deployer, becomes aware of the serious incident

- Derived: Probable The Digital Omnibus on AI deferred high-risk AI system obligations under the AI Act to 2 December 2027 for Annex III use-cases and 2 August 2028 for Annex I product-safety routes.Confidence: Probable (capped: best source is T3) · As of 9 Aug 2026 · EvidencedEvidence and sources[Legalithm](https://www.legalithm.com/en/ai-act-guide/article-26-deployer-obligations) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113(c)Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support.

- The Central Bank of Ireland is designated as Ireland's market surveillance authority under Article 74(6) of the AI Act for high-risk AI systems used by financial institutions.Confidence: Probable · As of 25 Jul 2025 · Carried forwardEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2025/si/366/made/en/print) T1 · Retrieved · retrieved 10 Nov 2026The Central Bank of Ireland is designated as the market surveillance authority for the purposes of Article 74(6).

- The Data Protection Commission is designated as Ireland's market surveillance authority under Article 74(8) of the AI Act for high-risk AI systems in law enforcement, migration, justice and specified biometric uses under Annex III.Confidence: Probable · As of 25 Jul 2025 · Carried forwardEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2025/si/366/made/en/print) T1 · Retrieved · retrieved 10 Nov 2026The Central Bank of Ireland is designated as the market surveillance authority for the purposes of Article 74(6).

- The AI Office of Ireland became operational on 1 August 2026 as Ireland's Article 70(2) single point of contact for the AI Act, superseding the interim ministerial designation.Confidence: Confirmed · As of 1 Aug 2026 · EvidencedEvidence and sources[AI Office of Ireland](https://aioffice.gov.ie/about-us/what-we-do/) T1 · Retrieved · retrieved 10 Nov 2026Now operational, the Office provides strategic governance in relation to the AI Act
- [imiel.dev](https://imiel.dev/explore/eu-ai-act-2026/ireland/) T3 · Retrieved · retrieved 10 Nov 2026Ireland's Regulation of AI Act 2026 commenced 31 July 2026, creating the AI Office of Ireland alongside 15 designated regulators

- Under the Digital Omnibus amendment, the AI Act's high-risk provider and importer/distributor obligations now apply from 2 December 2027 (Annex III systems) and 2 August 2028 (Annex I systems), later than the original Article 113 schedule.Confidence: Probable (capped: best source is T3) · Carried forwardEvidence and sources[ai-act-law.eu](https://ai-act-law.eu/article/113/) T3 · Retrieved · retrieved 10 Nov 2026Articles 102 to 110 shall apply from 27 July 2026.
- [EdLaw](https://edlaw.eduverse.com/docs/jurisdiction/int/eu/ai-act/APPLICATION-TIMELINE.md) T3 · Retrieved · retrieved 10 Nov 2026as amended by Regulation (EU) 2026/1744, which restructured the Article 113 timeline
- [ismscopilot.com](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 10 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027

- A Bill initiated in the Dáil on 4 February 2026 would extend Ireland's Coco's Law to intimate images generated or modified by computer graphics (AI/deepfakes); it has not yet been enacted.Confidence: Confirmed · As of 4 Feb 2026 · EvidencedEvidence and sources[Houses of the Oireachtas](https://www.oireachtas.ie/en/bills/bill/2026/13/) T1 · Retrieved · retrieved 10 Nov 2026Bill entitled an Act to amend the law relating to the recording, distribution or publication of intimate images

- Ireland established the AI Office of Ireland by statute, with functions to coordinate competent authorities, raise AI literacy, and advise the Minister, acting independently.Confidence: Probable · As of 21 Jul 2026 · EvidencedEvidence and sources[Irish Statute Book (Office of the Attorney General)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/print.html) T1 · Retrieved · retrieved 10 Nov 2026(1) The Office shall, in addition to the carrying out of other functions conferred on it by this Act or any other enactment— (a) coordinate the activities of relevant competent authorities to encourage consistent implementation and supervision of the Artificial Intelligence Regulation,

- Ireland's Regulation of Artificial Intelligence Act 2026 was signed into law on 21 July 2026 and its main provisions came into operation on 31 July 2026.Confidence: Probable · As of 31 Jul 2026 · EvidencedEvidence and sources[Matheson (via Mondaq)](https://mondaq.com/ireland/technology/1825130/irish-artificial-intelligence-act-2026-signed-into-law) T3 · Surfaced · retrieved 10 Nov 2026Ireland's Regulation of Artificial Intelligence Act 2026 has been signed into law, establishing the AI Office of Ireland as the central coordinating authority for EU AI Act compliance.
- [Hayes Solicitors](https://hayes-solicitors.ie/news/establishment-of-the-irish-ai-office/) T3 · Retrieved · retrieved 10 Nov 2026On 2 August 2026, the new Irish AI Office became operational.
- [Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/news-and-events/department-news/2026/july/20260730.html) T1 · Retrieved · retrieved 10 Nov 2026The Office is expected to be operational by 2 August 2026 and will provide strategic governance in relation to the AI Act while facilitating a coordinated and consistent regulatory approach across Ireland's designated competent authorities.

### 02Prohibited PracticesActive Derived: Probable▾#

AI Act (Regulation (EU) 2024/1689) (Valid from 2024-08-01).

3 instruments (3 current) · 1 obligation · 9 claims · 1 milestone · Next: 2 Dec 2026 (New Art 5(1)(ba)/(bb) prohibitions apply)

Article 5(1)(a)-(h) of Regulation (EU) 2024/1689 (the EU AI Act), in force in Ireland since 2 February 2025, prohibits providers and deployers from placing on the market, putting into service or using AI systems for eight listed practices, including subliminal or manipulative techniques, exploitation of vulnerabilities, social scoring, certain criminal-offence profiling, untargeted facial-image scraping, and workplace or educational emotion inference, each subject to narrow exceptions, including a law-enforcement exception for real-time remote biometric identification. Breach of Article 5 carries administrative fines of up to EUR 35,000,000 or 7% of worldwide annual turnover, whichever is higher, with the usual lower-of rule reversed for SMEs; other AI Act obligations attract fines of up to EUR 15,000,000 or 3% of turnover, and the provision of misleading information to authorities attracts fines of up to EUR 7,500,000 or 1% of turnover.

Regulation (EU) 2026/1744 (the Digital Omnibus on AI) adds two further prohibited practices to Article 5(1): AI-generated non-consensual intimate imagery and AI-generated or AI-facilitated child sexual abuse material. Both new prohibitions apply in Ireland from 2 December 2026.

Coimisiún na Meán is designated as an Irish AI Act market surveillance authority with supervisory responsibility for prohibited-practice and transparency obligations within its regulated media sector. Ireland's AI Advisory Council has stated that national law already criminalises AI-generated non-consensual intimate images and CSAM, and has urged EU-level amendment of Article 5 during Ireland's 2026 Presidency of the Council of the EU.

Read full sub-brief · 236 words

Instruments (3)
- AI Act (Regulation (EU) 2024/1689) Valid from 2024-08-01Binding
- Digital Omnibus on AI (Regulation (EU) 2026/1744) Valid from 2026-07-27Binding
- EU AI Act (Regulation (EU) 2024/1689) Valid from 2024-08-01Binding

Obligations

- Art 5(1)(a)-(h)Prohibits placing on market, putting into service or use of AI systems for subliminal manipulation, exploitation of vulnerabilities, social scoring, certain criminal profiling, untargeted facial-scraping, workplace/education emotion inference, biometric categorisation of sensitive attributes, and real-time remote biometric identification for law enforcement subject to narrow exception.Prohibition · Applies to: Provider · EU AI Act (Regulation (EU) 2024/1689)

Milestones

- 2 Dec 2026New Art 5(1)(ba)/(bb) prohibitions apply UpcomingAI Act (Regulation (EU) 2024/1689)

Claims and evidence (9)
- Non-compliance with Art 5 prohibited practices carries fines of up to EUR 35,000,000 or 7% of worldwide annual turnover, whichever is higher, with reversed SME caps.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99) T1 · Retrieved · retrieved 1 Nov 2026 · s.136Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to EUR 35 000 000

- Providers and deployers must not place on the market, put into service or use AI systems for eight listed prohibited practices under Art 5(1)(a)-(h), each subject to narrow exceptions.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Office)](https://ai-act-service-desk.ec.europa.eu/sites/default/files/2025-08/guidelines_on_prohibited_artificial_intelligence_practices_established_by_regulation_eu_20241689_ai_act_english_ied3r5nwo50xggpcfmwckm3nuc_112367-1.PDF) T1 · Retrievedthe placing on the market, putting into service or use of an AI system that deploys subliminal techniques beyond a person's consciousness

- Two new prohibited practices were added to Art 5(1): AI-generated non-consensual intimate imagery and AI-generated/facilitated CSAM, applying from 2 December 2026.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[aiactblog.nl](https://www.aiactblog.nl/en/ai-act/bijlage/3) T3 · Surfaced · retrieved 1 Nov 2026 · ss.59-60the relevant market surveillance authority may permit the applicant to conduct testing of the AI system in real world conditions

- Coimisiún na Meán is designated an Irish AI Act market-surveillance authority for prohibited practices and transparency obligations in its regulated sector.Confidence: Probable · EvidencedEvidence and sources[Coimisiún na Meán](https://www.cnam.ie/industry-and-professionals/codes-legislation/legislation/eu-artificial-intelligence-act/) T1 · Retrieved · retrieved 1 Nov 2026Coimisiún na Meán is one of 15 Market Surveillance Authorities designated in Ireland to supervise compliance with the AI Act.

- Derived: Probable AI Act penalties are tiered up to EUR 35m/7% turnover for prohibited-practice breaches, EUR 15m/3% for other obligations, and EUR 7.5m/1% for misleading information, with a lower-of rule for SMEs.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99) T1 · Retrieved · retrieved 1 Nov 2026 · s.136Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to EUR 35 000 000

- Derived: Probable Article 5 of the EU AI Act prohibits a closed list of AI practices, including subliminal manipulation, social scoring and untargeted facial-image scraping, with a narrow law-enforcement exception for real-time remote biometric identification.Confidence: Probable (Capped from Confirmed: best source is T3) · EvidencedEvidence and sources[Praxikon](https://www.praxikon.com/en/ai-act/artikel/53) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(a)Article 53 requires: (a) preparing technical documentation (Annex XI), (b) sharing transparency information with downstream providers (Annex XII), (c) maintaining a policy to comply with EU copyright law, and (d) publishing a public summary of training data.

- Derived: Probable The Digital Omnibus on AI adds two new prohibited practices to Article 5 of the AI Act, both applicable from 2 December 2026.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regumatrix.eu](https://regumatrix.eu/compliance/open-source-ai) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(ba),(bb)Article 53(2) gives open-source GPAI model providers a partial exemption — no technical documentation, no downstream information package.

- Ireland's AI Advisory Council said national law already criminalises AI-generated non-consensual intimate images and CSAM, and urged EU-level amendment of Article 5 during Ireland's 2026 Presidency.Confidence: Confirmed · As of 16 Jan 2026 · EvidencedEvidence and sources[Department of Enterprise, Trade and Employment (DETE)](https://enterprise.gov.ie/en/news-and-events/department-news/2026/january/202601162.html) T1 · Retrieved · retrieved 10 Nov 2026Irish law is sufficiently robust to address the non-consensual sharing of AI generated intimate images
- [Irish Legal News](https://www.irishlegal.com/articles/ireland-told-to-use-eu-presidency-to-push-for-stronger-ai-deepfake-law) T2 · Retrieved · retrieved 10 Nov 2026most effective response to the onset of technologies which allow for the production and publication

- The EU AI Act's Digital Omnibus amendment adds prohibitions on AI-generated non-consensual intimate imagery and CSAM, applying in Ireland from 2 December 2026.Confidence: Probable (capped: best source is T3) · As of 24 Jul 2026 · EvidencedEvidence and sources[euaiact.com](https://www.euaiact.com/digital-omnibus-ai) T3 · Retrieved · retrieved 10 Nov 2026The Digital Omnibus inserted Article 5(1)(ba) on non-consensual intimate imagery and Article 5(1)(bb) on child sexual abuse material, both applying from 2 December 2026.
- [Global Suite Solutions](https://www.globalsuitesolutions.com/digital-omnibus-ai-regulation-2026-1744/) T3 · Retrieved · retrieved 10 Nov 2026Both apply from 2 December 2026 and fall into the highest fine bracket: up to EUR 35 million or 7% of worldwide annual turnover.

### 03High-Risk SystemsActive Derived: Probable▾#

Digital Omnibus on AI (Regulation (EU) 2026/1744) (Valid from 2026-07-27).

2 instruments (2 current) · 0 obligations · 23 claims · 0 milestones

Regulation (EU) 2024/1689 (the EU AI Act) classifies an AI system as high-risk where it is a safety component of a regulated product within Annex I, or falls within one of the eight Annex III use-case categories: biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration/asylum/border control, and administration of justice; Annex III is amendable by Commission delegated act. Regulation (EU) 2026/1744 (the Digital Omnibus on AI) has deferred the Chapter III Sections 1-3 high-risk obligations: for Annex III use-case systems, from 2 August 2026 to 2 December 2027, and for Annex I product-safety route systems to 2 August 2028.

Once applicable, providers of high-risk AI systems must operate a quality management system, keep technical documentation and automatically generated logs, undergo conformity assessment, affix CE marking, register the system, and cooperate with authorities, retaining documentation for ten years after market placement. Conformity-assessment routes differ by Annex classification, with only biometric systems under Annex III point 1 generally requiring third-party notified-body assessment. A non-EU provider of a high-risk AI system must appoint, by written mandate, an EU-established authorised representative before making the system available on the Union market; authorised representatives, importers and distributors owe verification and cooperation duties, though the full detail of those sub-duties could not be confirmed. Deployers of high-risk AI systems must use the system according to its instructions, assign competent human oversight, monitor its operation, retain automatically generated logs for at least six months, and inform affected workers and their representatives. Public-body deployers, and specified private deployers in public-service, credit or insurance risk-assessment contexts, must carry out and register a fundamental rights impact assessment before first use of a high-risk AI system. Providers of high-risk systems, and deployers where applicable, must report serious incidents to the relevant market surveillance authority within tiered deadlines of 15 days generally, 2 days for widespread infringements or critical-infrastructure disruption, and 10 days where a person has died.

Read full sub-brief · 317 words

Instruments (2)
- Digital Omnibus on AI (Regulation (EU) 2026/1744) Valid from 2026-07-27Binding
- EU AI Act (Regulation (EU) 2024/1689) Valid from 2024-08-01Binding

Claims and evidence (23)
- The Digital Omnibus on AI deferred Chapter III Sections 1-3 high-risk obligations for Annex III use-case systems from 2 August 2026 to 2 December 2027.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[ISMS Copilot](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 1 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027 (Annex III) and 2 August 2028 (Annex I product route).

- High-risk obligations for AI systems under Art 6(1)/Annex I (safety components of regulated products) now apply from 2 August 2028.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[ISMS Copilot](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 1 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027 (Annex III) and 2 August 2028 (Annex I product route).

- A non-EU provider of a high-risk AI system must appoint by written mandate an EU authorised representative before making the system available on the Union market.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act-explorer) T1 · Retrieved · retrieved 1 Nov 2026 · s.1Article 22: Authorised representatives of providers of high-risk AI systems

- Annex III lists eight high-risk AI use-case categories (biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration/asylum/border control, administration of justice), amendable by Commission delegated act.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[aiactblog.nl](https://www.aiactblog.nl/en/ai-act/bijlage/3) T3 · Surfaced · retrieved 1 Nov 2026 · S.I. No. 405 of 2026AI systems intended to be used for biometric categorisation, according to sensitive or protected attributes or characteristics based on the inference of those attributes or characteristics

- Providers of high-risk AI systems must operate a QMS, keep technical documentation and logs, undergo conformity assessment, affix CE marking, register the system, and cooperate with authorities.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-16) T1 · Retrieved · retrieved 1 Nov 2026comply with the registration obligations referred to in Article 49(1)

- Providers (and deployers where applicable) must report serious incidents to the relevant market surveillance authority within 15 days generally, 2 days for widespread infringements or critical-infrastructure disruption, or 10 days where a person has died.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113not later than 15 days after the provider or, where applicable, the deployer, becomes aware of the serious incident

- Deployers of high-risk AI systems must use the system per instructions, assign competent human oversight, monitor operation, retain automatically generated logs for at least six months, and inform affected workers and their representatives.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Legalithm](https://www.legalithm.com/en/ai-act-guide/article-26-deployer-obligations) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113(c)Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support.

- Public-body deployers, and private deployers in specified contexts (public services, credit/insurance risk assessment), must carry out and register a fundamental rights impact assessment before first use of a high-risk AI system.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[agentliability.eu](https://agentliability.eu/articles/eu-ai-act-article-26-deployer-obligations-complete-guide) T3 · Retrieved · retrieved 1 Nov 2026Article 27 requires a fundamental rights impact assessment before first use for public-body deployers and deployers in high-exposure contexts including employment, credit, insurance, and essential services.

- Authorised representatives, importers and distributors of high-risk AI systems owe verification and cooperation duties before making a system available, but the detailed sub-duties were not fully retrievable.Confidence: Uncertain · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act-explorer) T1 · Retrieved · retrieved 1 Nov 2026 · s.1Article 22: Authorised representatives of providers of high-risk AI systems

- The Digital Omnibus on AI defers Annex III high-risk obligations to 2 December 2027.Confidence: Probable (capped: best source is T3) · As of 9 Aug 2026 · EvidencedEvidence and sources[ISMS Copilot](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 1 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027 (Annex III) and 2 August 2028 (Annex I product route).

- The Digital Omnibus on AI defers Annex I product-route high-risk obligations to 2 August 2028.Confidence: Probable (capped: best source is T3) · As of 9 Aug 2026 · EvidencedEvidence and sources[ISMS Copilot](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 1 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027 (Annex III) and 2 August 2028 (Annex I product route).

- A non-EU high-risk AI system provider must appoint an EU-established authorised representative before market availability.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act-explorer) T1 · Retrieved · retrieved 1 Nov 2026 · s.1Article 22: Authorised representatives of providers of high-risk AI systems

- An AI system is high-risk if it is a regulated product safety component (Annex I) or falls within one of the eight Annex III use-case categories.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[CMS DigitalLaws](https://www.cms-digitallaws.com/en/ai-act/article-6/) T3 · Retrieved · retrieved 1 Nov 2026an AI system referred to in Annex III shall not be considered to be high-risk where it does not pose a significant risk of harm to the health, safety or fundamental rights of natural persons

- Annex III lists eight high-risk AI use-case categories spanning biometrics, infrastructure, education, employment, essential services, law enforcement, migration and justice.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[aiactblog.nl](https://www.aiactblog.nl/en/ai-act/bijlage/3) T3 · Surfaced · retrieved 1 Nov 2026 · S.I. No. 405 of 2026AI systems intended to be used for biometric categorisation, according to sensitive or protected attributes or characteristics based on the inference of those attributes or characteristics

- High-risk AI system providers owe conformity-assessment, documentation, registration, CE-marking and cooperation duties.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-16) T1 · Retrieved · retrieved 1 Nov 2026comply with the registration obligations referred to in Article 49(1)

- High-risk AI system providers must retain documentation for 10 years after market placement.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-18) T1 · Retrieved · retrieved 1 Nov 2026for a period ending 10 years after the high-risk AI system has been placed on the market or put into service

- Deployers of high-risk AI systems owe human-oversight, monitoring, log-retention, worker-notification and cooperation duties.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Legalithm](https://www.legalithm.com/en/ai-act-guide/article-26-deployer-obligations) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113(c)Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support.
- [kla.digital](https://kla.digital/blog/eu-ai-act-article-26-deployer-obligations-runtime-checklist) T3 · Retrieved · retrieved 1 Nov 2026Article 26(6) requires automatically generated logs under the deployer's control to be kept for a period appropriate to the intended purpose and for at least six months

- Public-body and specified private deployers must conduct and register a fundamental rights impact assessment before deploying certain high-risk AI systems.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[agentliability.eu](https://agentliability.eu/articles/eu-ai-act-article-26-deployer-obligations-complete-guide) T3 · Retrieved · retrieved 1 Nov 2026Article 27 requires a fundamental rights impact assessment before first use for public-body deployers and deployers in high-exposure contexts including employment, credit, insurance, and essential services.

- Derived: Probable Providers of high-risk AI systems must meet Article 16 duties including QMS, documentation, conformity assessment and registration, though Annex III application is deferred to 2 December 2027.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulation-ai.eu](https://www.regulation-ai.eu/en/articles/article-52/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 16the provider must notify the Commission without delay and in any event within two weeks

- Derived: Probable The Digital Omnibus on AI deferred high-risk AI system obligations under the AI Act to 2 December 2027 for Annex III use-cases and 2 August 2028 for Annex I product-safety routes.Confidence: Probable (capped: best source is T3) · As of 9 Aug 2026 · EvidencedEvidence and sources[Legalithm](https://www.legalithm.com/en/ai-act-guide/article-26-deployer-obligations) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113(c)Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support.

- The AI Act sets different conformity-assessment routes for high-risk systems depending on Annex classification, with only biometric (Annex III point 1) systems generally requiring notified-body assessment.Confidence: Probable · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-18) T1 · Retrieved · retrieved 1 Nov 2026 · Art 43(2)Article 43(2) puts points 2 to 8 of Annex III on this route, "without the involvement of a notified body".

- Under the Digital Omnibus amendment, the AI Act's high-risk provider and importer/distributor obligations now apply from 2 December 2027 (Annex III systems) and 2 August 2028 (Annex I systems), later than the original Article 113 schedule.Confidence: Probable (capped: best source is T3) · Carried forwardEvidence and sources[ai-act-law.eu](https://ai-act-law.eu/article/113/) T3 · Retrieved · retrieved 10 Nov 2026Articles 102 to 110 shall apply from 27 July 2026.
- [EdLaw](https://edlaw.eduverse.com/docs/jurisdiction/int/eu/ai-act/APPLICATION-TIMELINE.md) T3 · Retrieved · retrieved 10 Nov 2026as amended by Regulation (EU) 2026/1744, which restructured the Article 113 timeline
- [ismscopilot.com](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 10 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027

- Under Article 22(1) of the AI Act, a third-country provider of a high-risk AI system must appoint an EU-established authorised representative by written mandate before placing the system on the EU market.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[ai-act.io](https://en.ai-act.io/article/high-risk-ai-systems/obligations-of-providers-and-deployers-of-high-risk-ai-systems-and-other-parties/authorised-representatives-of-providers-of-high-risk-ai-systems) T3 · Retrieved · retrieved 10 Nov 2026providers established in third countries shall, by written mandate, appoint an authorised representative
- [artificialintelligenceact.eu](https://artificialintelligenceact.eu/article/22/) T3 · Retrieved · retrieved 10 Nov 2026Comes into force 2 December 2027 (high-risk under Annex III) / 2 August 2028

### 04General-Purpose AIActive Derived: Probable▾#

A GPAI model is presumed to present systemic risk above 10^25 FLOPs cumulative training compute, and its provider must notify the Commission without delay and within two weeks of meeting or foreseeing that threshold, with an option to rebut the presumption.

0 instruments (0 current) · 2 obligations · 6 claims · 0 milestones

Under Regulation (EU) 2024/1689 (the EU AI Act), providers of general-purpose AI models must maintain technical documentation, give downstream providers information on the model's capabilities and limitations, maintain a copyright-compliance policy, and publish a summary of training content. Open-source models benefit from a partial exemption covering only the technical-documentation and downstream-information duties; the copyright-policy and training-content-summary duties apply regardless of open-source status.

A general-purpose AI model is presumed to present systemic risk where its cumulative training compute exceeds 10^25 FLOPs; its provider must notify the European Commission without delay and within two weeks of meeting or foreseeing that threshold, with an option to rebut the presumption. A provider of a systemic-risk general-purpose AI model must additionally perform model evaluation, risk mitigation, cybersecurity assurance, and serious-incident reporting.

Cited evidence in this module rests solely on tier 3/4 commentary despite primary official sources existing for this jurisdiction.

Obligations

- Art 53(1)(a)-(d), Art 53(2)GPAI providers must keep technical documentation, downstream information, copyright policy and training-content summary; open-source exemption limited and void for systemic-risk models.Documentation · Applies to: Provider · EU AI Act (Regulation (EU) 2024/1689)
- Art 51(2), Art 52(1)-(2)GPAI providers meeting/foreseeing the 10^25 FLOPs threshold must notify the Commission within two weeks.Other · Applies to: Provider · EU AI Act (Regulation (EU) 2024/1689)

Claims and evidence (6)
- Derived: Probable A GPAI model is presumed to present systemic risk above 10^25 FLOPs cumulative training compute, and its provider must notify the Commission without delay and within two weeks of meeting or foreseeing that threshold, with an option to rebut the presumption.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulation-ai.eu](https://www.regulation-ai.eu/en/articles/article-52/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 16the provider must notify the Commission without delay and in any event within two weeks

- Providers of general-purpose AI models must maintain technical documentation, give downstream providers capability/limitation information, maintain a copyright-compliance policy, and publish a training-content summary; open-source models are exempt from the first two duties but never the latter two, and never when systemic risk applies.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Praxikon](https://www.praxikon.com/en/ai-act/artikel/53) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(a)Article 53 requires: (a) preparing technical documentation (Annex XI), (b) sharing transparency information with downstream providers (Annex XII), (c) maintaining a policy to comply with EU copyright law, and (d) publishing a public summary of training data.

- A GPAI model is presumed systemic-risk above 10^25 FLOPs cumulative training compute; the provider must notify the Commission within two weeks of meeting or foreseeing that threshold.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulation-ai.eu](https://www.regulation-ai.eu/en/articles/article-52/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 16the provider must notify the Commission without delay and in any event within two weeks

- GPAI model providers must keep technical documentation, inform downstream providers, maintain a copyright policy, and publish a training-content summary, with a partial open-source exemption.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Praxikon](https://www.praxikon.com/en/ai-act/artikel/53) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(a)Article 53 requires: (a) preparing technical documentation (Annex XI), (b) sharing transparency information with downstream providers (Annex XII), (c) maintaining a policy to comply with EU copyright law, and (d) publishing a public summary of training data.
- [regumatrix.eu](https://regumatrix.eu/compliance/open-source-ai) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(ba),(bb)Article 53(2) gives open-source GPAI model providers a partial exemption — no technical documentation, no downstream information package.

- A GPAI provider whose model's cumulative training compute exceeds 10^25 FLOPs must notify the Commission within two weeks.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulation-ai.eu](https://www.regulation-ai.eu/en/articles/article-52/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 16the provider must notify the Commission without delay and in any event within two weeks

- A systemic-risk GPAI provider must perform model evaluation, risk mitigation, cybersecurity assurance, and serious-incident reporting.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[aiact-checker.com](https://aiact-checker.com/en/topics/general-purpose-ai) T3 · Retrieved · retrieved 1 Nov 2026Systemic-risk duties (Article 55): Model evaluation, adversarial testing, incident reporting and cybersecurity.

### 05Transparency & Synthetic ContentActive Derived: Probable▾#

EU AI Act (Regulation (EU) 2024/1689) (Valid from 2024-08-01).

1 instrument (1 current) · 1 obligation · 3 claims · 0 milestones

Article 50 of Regulation (EU) 2024/1689 (the EU AI Act) has applied in Ireland since 2 August 2026. It requires disclosure of AI interaction to natural persons, machine-detectable marking of synthetic content, disclosure of emotion-recognition or biometric-categorisation system use, and labelling of deepfakes and AI-generated public-interest text, subject to the Act's artistic and editorial exceptions.

A Bill initiated in the Dáil on 4 February 2026 would extend Ireland's Harassment, Harmful Communications and Related Offences Act 2020 (Coco's Law) to intimate images generated or modified by computer graphics, including AI-generated deepfakes; the Bill has not yet been enacted.

Instruments (1)
- EU AI Act (Regulation (EU) 2024/1689) Valid from 2024-08-01Binding

Obligations

- Art 50(1)-(5)Providers and deployers must disclose AI interaction, mark synthetic content, and label deepfakes/public-interest AI text, subject to artistic and editorial exceptions.Transparency disclosure · Applies to: Provider · EU AI Act (Regulation (EU) 2024/1689)

Claims and evidence (3)
- Derived: Probable Article 50 transparency obligations of the EU AI Act, covering AI-interaction disclosure, synthetic-content marking, emotion-recognition/biometric-categorisation disclosure and deepfake/public-interest-text disclosure, have applied since 2 August 2026.Confidence: Probable (capped: best source is T3) · As of 2 Aug 2026 · EvidencedEvidence and sources[Paul, Weiss](https://www.paulweiss.com/insights/client-memos/eu-finalises-transparency-rules-for-ai-generated-content) T3 · RetrievedProviders must tell users when they are dealing with an AI system and mark AI-generated content so it can be detected as such, and deployers must flag more sensitive uses
- [Peterka Partners](https://blog.peterkapartners.com/article-50-of-the-ai-act-in-practice-transparency-of-ai-systems-content-labeling-and-deepfakes/) T3 · RetrievedAs of August 2, 2026, the transparency obligations under Article 50 of Regulation (EU) 2024/1689 (the AI Act) apply.
- [Morgan Lewis](https://www.morganlewis.com/blogs/sourcingatmorganlewis/2026/08/eu-ai-acts-transparency-rules-what-went-into-effect-on-2-august) T3 · RetrievedThe requirements concerning emotion recognition, biometric categorisation, deepfakes, and relevant public-interest text have applied since 2 August 2026.

- Derived: Probable Article 50 of the AI Act, in force since 2 August 2026, requires disclosure of AI interaction, machine-detectable marking of synthetic content, and labelling of deepfakes and AI-generated public-interest text.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Trussed](https://trussed.ai/resources/eu-ai-act-article-73-serious-incident-reporting-timelines) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50That window shortens to 10 days for incidents involving death and 2 days for serious, irreversible disruption of critical infrastructure
- [Legalithm](https://www.legalithm.com/en/ai-act-guide/article-26-deployer-obligations) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50As of August 2, 2026, the transparency obligations under Article 50 of Regulation (EU) 2024/1689 (the AI Act) apply.
- [kla.digital](https://kla.digital/blog/eu-ai-act-article-26-deployer-obligations-runtime-checklist) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50The requirements concerning emotion recognition, biometric categorisation, deepfakes, and relevant public-interest text have applied since 2 August 2026.

- A Bill initiated in the Dáil on 4 February 2026 would extend Ireland's Coco's Law to intimate images generated or modified by computer graphics (AI/deepfakes); it has not yet been enacted.Confidence: Confirmed · As of 4 Feb 2026 · EvidencedEvidence and sources[Houses of the Oireachtas](https://www.oireachtas.ie/en/bills/bill/2026/13/) T1 · Retrieved · retrieved 10 Nov 2026Bill entitled an Act to amend the law relating to the recording, distribution or publication of intimate images

### 06AI & Intellectual PropertyActive Derived: Probable▾#

Providers of general-purpose AI models must maintain technical documentation, give downstream providers model information, maintain an EU-copyright compliance policy, and publish a training-data summary, with a partial exemption for open-source models that never covers the copyright or training-data-summary duties and does not apply at all to systemic-risk models.

0 instruments (0 current) · 0 obligations · 4 claims · 0 milestones

Under Regulation (EU) 2024/1689 (the EU AI Act), providers of general-purpose AI models must maintain technical documentation, give downstream providers model information, maintain a copyright-compliance policy consistent with EU copyright law, and publish a summary of training data content. A partial open-source exemption applies only to the technical-documentation and downstream-information duties; it never extends to the copyright-policy or training-data-summary duties. These duties attach irrespective of a model's systemic-risk status, which is assessed separately against the Act's 10^25 FLOPs cumulative training-compute threshold triggering a two-week Commission notification duty.

Cited evidence in this module rests solely on tier 3/4 commentary despite primary official sources existing for this jurisdiction.

Claims and evidence (4)
- Providers of general-purpose AI models must maintain technical documentation, give downstream providers model information, maintain an EU-copyright compliance policy, and publish a training-data summary, with a partial exemption for open-source models that never covers the copyright or training-data-summary duties and does not apply at all to systemic-risk models.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Praxikon](https://www.praxikon.com/en/ai-act/artikel/53) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(a)Article 53 requires: (a) preparing technical documentation (Annex XI), (b) sharing transparency information with downstream providers (Annex XII), (c) maintaining a policy to comply with EU copyright law, and (d) publishing a public summary of training data.
- [regumatrix.eu](https://regumatrix.eu/compliance/open-source-ai) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(ba),(bb)Article 53(2) gives open-source GPAI model providers a partial exemption — no technical documentation, no downstream information package.

- Derived: Probable A GPAI model is presumed to present systemic risk above 10^25 FLOPs cumulative training compute, and its provider must notify the Commission without delay and within two weeks of meeting or foreseeing that threshold, with an option to rebut the presumption.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulation-ai.eu](https://www.regulation-ai.eu/en/articles/article-52/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 16the provider must notify the Commission without delay and in any event within two weeks

- Providers of general-purpose AI models must maintain technical documentation, give downstream providers capability/limitation information, maintain a copyright-compliance policy, and publish a training-content summary; open-source models are exempt from the first two duties but never the latter two, and never when systemic risk applies.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Praxikon](https://www.praxikon.com/en/ai-act/artikel/53) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(a)Article 53 requires: (a) preparing technical documentation (Annex XI), (b) sharing transparency information with downstream providers (Annex XII), (c) maintaining a policy to comply with EU copyright law, and (d) publishing a public summary of training data.

- GPAI model providers must keep technical documentation, inform downstream providers, maintain a copyright policy, and publish a training-content summary, with a partial open-source exemption.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Praxikon](https://www.praxikon.com/en/ai-act/artikel/53) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(a)Article 53 requires: (a) preparing technical documentation (Annex XI), (b) sharing transparency information with downstream providers (Annex XII), (c) maintaining a policy to comply with EU copyright law, and (d) publishing a public summary of training data.
- [regumatrix.eu](https://regumatrix.eu/compliance/open-source-ai) T3 · Retrieved · retrieved 1 Nov 2026 · Art 5(1)(ba),(bb)Article 53(2) gives open-source GPAI model providers a partial exemption — no technical documentation, no downstream information package.

### 07Sectoral & Public-Sector AIActive▾#

Harassment, Harmful Communications and Related Offences Act 2020 (In force since 2021-02-10).

2 instruments (2 current) · 1 obligation · 9 claims · 1 milestone · Next: 2 Aug 2027 (EU-level AI regulatory sandbox operational deadline (deferred))

Under section 59(1) of the Regulation of Artificial Intelligence Act 2026, a relevant fundamental rights public body must inform the relevant market surveillance authority, as soon as reasonably practicable, when it makes an Article 77(1) access request under the EU AI Act; high-risk AI system providers more generally must retain required documentation for ten years after market placement. Separately, Ireland's Harassment, Harmful Communications and Related Offences Act 2020 (Coco's Law) criminalises the non-consensual distribution of intimate images and is understood to extend to AI-generated or digitally altered images.

The Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation has published non-binding Guidelines for the Responsible Use of AI in the Public Service, first issued 7 May 2025 and last updated 31 October 2025. The Guidelines set out seven Trustworthy AI principles, a Decision Framework and a Responsible AI Canvas for public bodies, require that all AI tools used in the public service be part of a process with built-in human oversight, and operate as soft law carrying no direct statutory penalties.

Ireland's national AI strategy, refreshed in November 2024, is a non-binding whole-of-government policy framework that references coordination with the Data Protection Commission; it sits alongside, and does not substitute for, the binding duties under the EU AI Act and the Regulation of Artificial Intelligence Act 2026. Ireland's AI Advisory Council has stated that national law already criminalises AI-generated non-consensual intimate images and CSAM, and has urged EU-level amendment of Article 5 of the AI Act during Ireland's 2026 Presidency of the Council of the EU.

Read full sub-brief · 257 words

Instruments (2)
- Harassment, Harmful Communications and Related Offences Act 2020 In force since 2021-02-10Binding
- Regulation of Artificial Intelligence Act 2026 In force since 2026-07-31Binding

Obligations

- s.59(1)A relevant fundamental rights public body must inform the relevant market surveillance authority as soon as reasonably practicable on making an Article 77(1) access request.Transparency disclosure · Applies to: Other · Regulation of Artificial Intelligence Act 2026

Milestones

- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) UpcomingRegulation of Artificial Intelligence Act 2026

Claims and evidence (9)
- The Guidelines for the Responsible Use of AI in the Public Service, published 7 May 2025 and last updated 31 October 2025, set out seven principles, a Decision Framework and a Responsible AI Canvas, as non-binding soft law imposing no direct statutory penalties.Confidence: Probable · EvidencedEvidence and sources[Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation](https://assets.gov.ie/static/documents/09fe3ad4/Guidelines_for_the_Responsible_Use_of_AI_in_the_Public_Service_20250918.pdf) T1 · Retrieved · retrieved 10 Nov 2026All AI tools used in the public service must be part of a process that has human oversight built into it.
- [Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation](https://www.gov.ie/en/department-of-public-expenditure-infrastructure-public-service-reform-and-digitalisation/publications/guidelines-for-the-responsible-use-of-ai-in-the-public-service/) T1 · Surfaced · retrieved 7 May 2025The Guidelines for the Responsible Use of Artificial Intelligence in the Public Service have been developed to actively empower public servants to use Artificial Intelligence (AI) in the delivery of services.

- Ireland's national AI strategy, refreshed in November 2024, is a non-binding whole-of-government policy framework that references coordination with the Data Protection Commission and does not substitute binding AI Act/national AI Act duties.Confidence: Probable · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-18) T1 · Retrieved · retrieved 1 Nov 2026 · Art 43(2)Article 43(2) puts points 2 to 8 of Annex III on this route, "without the involvement of a notified body".

- High-risk AI system providers must retain documentation for 10 years after market placement.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-18) T1 · Retrieved · retrieved 1 Nov 2026for a period ending 10 years after the high-risk AI system has been placed on the market or put into service

- Ireland's Department of Public Expenditure has published non-binding Guidelines for the Responsible Use of AI in the Public Service, setting seven principles and supporting tools for public bodies.Confidence: Probable · As of 7 May 2025 · EvidencedEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order

- Ireland's national AI strategy, refreshed in November 2024, is non-binding whole-of-government policy sitting alongside the binding EU AI Act and the Regulation of Artificial Intelligence Act 2026.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026In November 2024, the Irish government published a refresh of its national AI strategy titled "Ireland's National AI Strategy: AI – Here for Good"

- Ireland's AI Advisory Council said national law already criminalises AI-generated non-consensual intimate images and CSAM, and urged EU-level amendment of Article 5 during Ireland's 2026 Presidency.Confidence: Confirmed · As of 16 Jan 2026 · EvidencedEvidence and sources[Department of Enterprise, Trade and Employment (DETE)](https://enterprise.gov.ie/en/news-and-events/department-news/2026/january/202601162.html) T1 · Retrieved · retrieved 10 Nov 2026Irish law is sufficiently robust to address the non-consensual sharing of AI generated intimate images
- [Irish Legal News](https://www.irishlegal.com/articles/ireland-told-to-use-eu-presidency-to-push-for-stronger-ai-deepfake-law) T2 · Retrieved · retrieved 10 Nov 2026most effective response to the onset of technologies which allow for the production and publication

- Ireland's Coco's Law (2020) criminalises non-consensual distribution of intimate images and is understood to extend to AI-generated or digitally altered images.Confidence: Probable · As of 28 Dec 2020 · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/2020/act/32/enacted/en/xml) T1 · Retrieved · retrieved 10 Nov 2026A person who distributes, publishes or threatens to distribute or publish an intimate image of another person
- [Law Society of Ireland Gazette](https://www.lawsociety.ie/gazette/in-depth/2026/january-february/bad-robot/) T3 · Retrieved · retrieved 10 Nov 2026Irish law already criminalises both the non-consensual distribution of intimate images and the production of CSAM

- Irish fundamental rights public bodies must notify the relevant market surveillance authority as soon as reasonably practicable when making an Article 77(1) access request.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order

- Ireland's public-service AI guidelines require all AI tools used in government to comply with seven Trustworthy AI principles, including built-in human oversight.Confidence: Confirmed · As of 18 Sep 2025 · EvidencedEvidence and sources[Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation](https://assets.gov.ie/static/documents/09fe3ad4/Guidelines_for_the_Responsible_Use_of_AI_in_the_Public_Service_20250918.pdf) T1 · Retrieved · retrieved 10 Nov 2026All AI tools used in the public service must be part of a process that has human oversight built into it.

### 08Safety & Incident ReportingActive Derived: Probable▾#

EU AI Act (Regulation (EU) 2024/1689) (Valid from 2024-08-01).

2 instruments (2 current) · 2 obligations · 7 claims · 1 milestone · Next: 2 Aug 2027 (EU-level AI regulatory sandbox operational deadline (deferred))

Article 73 of Regulation (EU) 2024/1689 (the EU AI Act) requires providers of high-risk AI systems, and deployers where applicable, to report serious incidents to the relevant market surveillance authority within tiered deadlines: generally within 15 days of becoming aware of the incident, within 2 days for widespread infringements or serious and irreversible disruption to critical infrastructure, and within 10 days where a person has died. National market surveillance authorities in Ireland apply EU-wide procedures to act against AI systems presenting a risk, including corrective action, restriction, withdrawal or recall.

Under section 60(1)(b) of the Regulation of Artificial Intelligence Act 2026, a relevant market surveillance authority must report annually to the AI Office of Ireland and the Competition and Consumer Protection Commission all serious incidents of high-risk AI systems reported to it under Article 73.

Instruments (2)
- EU AI Act (Regulation (EU) 2024/1689) Valid from 2024-08-01Binding
- Regulation of Artificial Intelligence Act 2026 In force since 2026-07-31Binding

Obligations

- Art 73(1)-(4)Providers (deployers where applicable) must report serious incidents to the market surveillance authority within tiered deadlines.Incident reporting · Applies to: Provider · EU AI Act (Regulation (EU) 2024/1689)
- s.60(1)(b)A relevant market surveillance authority must report annually to the AI Office and the CCPC all serious incidents of high-risk AI systems reported under Article 73.Incident reporting · Applies to: Other · Regulation of Artificial Intelligence Act 2026

Milestones

- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) UpcomingRegulation of Artificial Intelligence Act 2026

Claims and evidence (7)
- Providers (and deployers where applicable) must report serious incidents to the relevant market surveillance authority within 15 days generally, 2 days for widespread infringements or critical-infrastructure disruption, or 10 days where a person has died.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113not later than 15 days after the provider or, where applicable, the deployer, becomes aware of the serious incident

- Derived: Probable Article 73 of the EU AI Act requires providers (and deployers where applicable) to report serious incidents involving high-risk AI systems within 15 days generally, 2 days for widespread infringement or critical-infrastructure disruption, and 10 days where death has occurred.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113not later than 15 days after the provider or, where applicable, the deployer, becomes aware of the serious incident
- [Trussed](https://trussed.ai/resources/eu-ai-act-article-73-serious-incident-reporting-timelines) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50That window shortens to 10 days for incidents involving death and 2 days for serious, irreversible disruption of critical infrastructure

- High-risk AI system providers must report serious incidents within tiered deadlines of 2, 10 or 15 days depending on severity.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113not later than 15 days after the provider or, where applicable, the deployer, becomes aware of the serious incident
- [Trussed](https://trussed.ai/resources/eu-ai-act-article-73-serious-incident-reporting-timelines) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50That window shortens to 10 days for incidents involving death and 2 days for serious, irreversible disruption of critical infrastructure

- Derived: Probable Article 73 of the AI Act requires providers and deployers to report serious incidents to market surveillance authorities within tiered deadlines of immediately, 15, 10 or 2 days depending on severity.Confidence: Probable · EvidencedEvidence and sources[regulations.ai](https://regulations.ai/eu-ai-act/ireland) T3 · Retrieved · retrieved 1 Nov 2026 · Art 73(1)Article 70 of the AI Act requires each EU Member State to establish or designate at least one notifying authority and at least one market surveillance authority
- [Irish Statute Book](https://www.irishstatutebook.ie/eli/2025/si/366/made/en) T1 · Retrieved · retrieved 1 Nov 2026 · Art 73The Data Protection Commission is designated as the market surveillance authority for the purposes of Article 74(8).

- Derived: Probable National market surveillance authorities in Ireland apply EU-wide procedures to act against AI systems that present a risk, including corrective action, restriction, withdrawal or recall.Confidence: Probable · As of 2 Aug 2026 · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/isbc/2026_31.html) T1 · Retrieved · retrieved 1 Nov 2026 · Art 79Ss. 1-77 | 31 July 2026 | Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2

- Under Article 73 of the AI Act, providers of high-risk AI systems must report a serious incident to the relevant market surveillance authority no later than 15 days after becoming aware, with shorter deadlines (10 days for death; 2 days for widespread infringement or critical-infrastructure disruption) applying to specific incident types.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[ai-act-law.eu](https://ai-act-law.eu/article/73/) T3 · Retrieved · retrieved 10 Nov 2026not later than 15 days after the provider or, where applicable, the deployer, becomes aware
- [euaiact.com](https://www.euaiact.com/article/73) T3 · Retrieved · retrieved 10 Nov 2026shall immediately notify the Commission of any serious incident, whether or not they have taken action

- Irish market surveillance authorities must report annually to the AI Office and CCPC all Article 73 serious incidents of high-risk AI systems in the State.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order

### 09Standards & ConformityActive Derived: Probable▾#

EU AI Act (Regulation (EU) 2024/1689) (Valid from 2024-08-01).

1 instrument (1 current) · 0 obligations · 7 claims · 0 milestones

Under Article 16 of Regulation (EU) 2024/1689 (the EU AI Act), providers of high-risk AI systems must comply with the Chapter III Section 2 requirements, including registration, technical documentation, a quality management system and conformity assessment; application of these duties to Annex III use-case systems is deferred to 2 December 2027 under the Digital Omnibus on AI. Article 43 sets differentiated conformity-assessment routes by Annex classification: Annex I safety-component systems follow the relevant sectoral product legislation; Annex III points 2 to 8 use internal control without a notified body; and Annex III point 1 (biometric systems) requires third-party notified-body assessment unless a harmonised standard applies. Articles 40 and 41 create a presumption of conformity for high-risk systems meeting cited harmonised standards or Commission common specifications, but no such harmonised standard had been cited in the Official Journal. Providers of high-risk systems, and deployers where applicable, remain subject to the Article 73 serious-incident reporting duty as part of the same conformity and post-market framework.

Instruments (1)
- EU AI Act (Regulation (EU) 2024/1689) Valid from 2024-08-01Binding

Claims and evidence (7)
- Derived: Probable Under Article 16 of the EU AI Act, providers of high-risk AI systems must comply with Chapter III Section 2 requirements, including registration, documentation, quality management and conformity assessment, with application deferred to 2 December 2027.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-16) T1 · Retrieved · retrieved 1 Nov 2026comply with the registration obligations referred to in Article 49(1)

- Derived: Probable Article 73 of the EU AI Act requires providers (and deployers where applicable) to report serious incidents involving high-risk AI systems within 15 days generally, 2 days for widespread infringement or critical-infrastructure disruption, and 10 days where death has occurred.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 113not later than 15 days after the provider or, where applicable, the deployer, becomes aware of the serious incident
- [Trussed](https://trussed.ai/resources/eu-ai-act-article-73-serious-incident-reporting-timelines) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50That window shortens to 10 days for incidents involving death and 2 days for serious, irreversible disruption of critical infrastructure

- Derived: Probable Articles 40 and 41 of the EU AI Act create a presumption of conformity for high-risk AI systems meeting cited harmonised standards or Commission common specifications, though no such harmonised standard had been cited in the Official Journal as of the run date.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Legalithm](https://www.legalithm.com/en/ai-act-guide/article-26-deployer-obligations) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50As of August 2, 2026, the transparency obligations under Article 50 of Regulation (EU) 2024/1689 (the AI Act) apply.

- Derived: Probable Article 43 of the EU AI Act sets differentiated conformity-assessment routes by annex: Annex I products follow relevant product legislation, Annex III points 2-8 use internal control without a notified body, and Annex III point 1 (biometrics) requires third-party assessment unless harmonised standards or common specifications are applied.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[kla.digital](https://kla.digital/blog/eu-ai-act-article-26-deployer-obligations-runtime-checklist) T3 · Retrieved · retrieved 1 Nov 2026 · Art 50The requirements concerning emotion recognition, biometric categorisation, deepfakes, and relevant public-interest text have applied since 2 August 2026.

- Derived: Probable Providers of high-risk AI systems must meet Article 16 duties including QMS, documentation, conformity assessment and registration, though Annex III application is deferred to 2 December 2027.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulation-ai.eu](https://www.regulation-ai.eu/en/articles/article-52/) T3 · Retrieved · retrieved 1 Nov 2026 · Art 16the provider must notify the Commission without delay and in any event within two weeks

- Articles 40-41 of the AI Act create a presumption of conformity for high-risk systems meeting harmonised standards or common specifications, but as of this cycle no such harmonised standard has been cited in the Official Journal.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Trussed](https://trussed.ai/resources/eu-ai-act-article-73-serious-incident-reporting-timelines) T3 · Retrieved · retrieved 1 Nov 2026 · Art 40Article 40(1) of the EU AI Act gives a presumption of conformity.

- The AI Act sets different conformity-assessment routes for high-risk systems depending on Annex classification, with only biometric (Annex III point 1) systems generally requiring notified-body assessment.Confidence: Probable · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-18) T1 · Retrieved · retrieved 1 Nov 2026 · Art 43(2)Article 43(2) puts points 2 to 8 of Annex III on this route, "without the involvement of a notified body".

### 10Authorities & EnforcementActive Derived: Probable▾#

European Union (Artificial Intelligence) (Designation) Regulations 2025 (Valid from 2025-09-16).

4 instruments (4 current) · 2 obligations · 21 claims · 1 milestone · Next: 2 Aug 2027 (EU-level AI regulatory sandbox operational deadline (deferred))

The Regulation of Artificial Intelligence Act 2026 (No. 31/2026) commenced on 31 July 2026, establishing the AI Office of Ireland as a body corporate and as Ireland's single point of contact under Article 70(2) of the EU AI Act, together with a national AI regulatory sandbox and a domestic enforcement and penalty regime. The AI Office became operational on 1 August 2026, superseding the interim ministerial designation, and the Act gives it statutory functions to coordinate competent authorities, raise AI literacy, and advise the Minister, acting independently. Article 70 of the AI Act separately requires Ireland to designate at least one notifying authority and at least one market surveillance authority.

Ireland designated 15 national competent authorities under Article 70(1) of the AI Act by the European Union (Artificial Intelligence) (Designation) Regulations 2025 (S.I. No. 366 of 2025), which names the Minister for Enterprise, Tourism and Employment as national competent authority and the Central Bank of Ireland and the Data Protection Commission among the market surveillance authorities. The Central Bank of Ireland is designated as market surveillance authority under Article 74(6) for high-risk AI systems used by financial institutions, and the Data Protection Commission is designated under Article 74(8) for high-risk AI systems in law enforcement, migration, justice and specified biometric uses under Annex III. The European Union (Artificial Intelligence) (Designation) Regulations 2026 (S.I. No. 405 of 2026) added further market-surveillance designations, including Coimisiún na Meán as one of the 15 market surveillance authorities, supervising Article 5(1)(a)-(b) and Article 50 obligations for entities in the media sector that it regulates, and updated the designation list to add the AI Office of Ireland.

Market surveillance authorities apply EU-wide procedures to act against AI systems presenting a risk, including corrective action, restriction, withdrawal or recall, and must report annually to the AI Office and the Competition and Consumer Protection Commission all serious incidents of high-risk AI systems reported to them under Article 73 of the AI Act. Non-compliance with the Article 5 prohibited practices carries fines of up to EUR 35,000,000 or 7% of worldwide annual turnover, whichever is higher, with the usual lower-of rule reversed for SMEs; other AI Act obligations carry fines of up to EUR 15,000,000 or 3% of turnover, and misleading information to authorities carries fines of up to EUR 7,500,000 or 1% of turnover. Section 136 of the Regulation of Artificial Intelligence Act 2026 caps administrative fines against public bodies for AI Act infringements at EUR 1,000,000.

Read full sub-brief · 409 words

Instruments (4)
- European Union (Artificial Intelligence) (Designation) Regulations 2025 Valid from 2025-09-16Binding
- European Union (Artificial Intelligence) (Designation) Regulations 2026 (further MSA designations) Date not recordedBinding
- Regulation of Artificial Intelligence Act 2026 Valid from 2026-07-31Binding
- Regulation of Artificial Intelligence Act 2026 In force since 2026-07-31Binding

Obligations

- s.136Public-body administrative fines for AI Act infringements capped at EUR 1,000,000.Other · Applies to: Other · Regulation of Artificial Intelligence Act 2026
- s.60(1)(b)A relevant market surveillance authority must report annually to the AI Office and the CCPC all serious incidents of high-risk AI systems reported under Article 73.Incident reporting · Applies to: Other · Regulation of Artificial Intelligence Act 2026

Milestones

- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) UpcomingRegulation of Artificial Intelligence Act 2026

Claims and evidence (21)
- S.I. No. 366 of 2025 designates the Data Protection Commission as the market surveillance authority for the purposes of Article 74(8) of the AI Act.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/2025/si/366/made/en) T1 · Retrieved · retrieved 1 Nov 2026 · Art 73The Data Protection Commission is designated as the market surveillance authority for the purposes of Article 74(8).

- The Regulation of Artificial Intelligence Act 2026 establishes the AI Office of Ireland as a body corporate and the single point of contact under Article 70(2) of the AI Act, commenced 31 July 2026.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/isbc/2026_31.html) T1 · Retrieved · retrieved 1 Nov 2026 · Art 79Ss. 1-77 | 31 July 2026 | Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2

- Section 136 of the Regulation of Artificial Intelligence Act 2026 caps administrative fines against public bodies for AI Act infringements at EUR 1,000,000.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/2026/act/31/section/136/enacted/en/html) T1 · Retrieved · retrieved 1 Nov 2026the amount of the fine shall not exceed €1,000,000.

- S.I. No. 405 of 2026 designates Coimisiun na Mean as one of 15 market surveillance authorities for the AI Act in Ireland, supervising Art 5(1)(a)-(b) and Art 50 obligations for entities it regulates.Confidence: Probable · EvidencedEvidence and sources[Coimisiún na Meán](https://www.cnam.ie/industry-and-professionals/codes-legislation/legislation/eu-artificial-intelligence-act/) T1 · Retrieved · retrieved 1 Nov 2026Coimisiún na Meán is one of 15 Market Surveillance Authorities designated in Ireland to supervise compliance with the AI Act.

- Non-compliance with Art 5 prohibited practices carries fines of up to EUR 35,000,000 or 7% of worldwide annual turnover, whichever is higher, with reversed SME caps.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99) T1 · Retrieved · retrieved 1 Nov 2026 · s.136Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to EUR 35 000 000

- Ireland must designate at least one notifying authority and one market-surveillance authority under Art 70 of the AI Act.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[regulations.ai](https://regulations.ai/eu-ai-act/ireland) T3 · Retrieved · retrieved 1 Nov 2026 · Art 73(1)Article 70 of the AI Act requires each EU Member State to establish or designate at least one notifying authority and at least one market surveillance authority

- S.I. No. 366 of 2025 designates the Minister, the Central Bank of Ireland and the Data Protection Commission as Irish AI Act authorities.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/2025/si/366/made/en) T1 · Retrieved · retrieved 1 Nov 2026 · Art 73The Data Protection Commission is designated as the market surveillance authority for the purposes of Article 74(8).

- Ireland's Regulation of Artificial Intelligence Act 2026 entered into force 31 July 2026, establishing the AI Office of Ireland, a sandbox, and an enforcement regime.Confidence: Probable · As of 31 Jul 2026 · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/isbc/2026_31.html) T1 · Retrieved · retrieved 1 Nov 2026 · Art 79Ss. 1-77 | 31 July 2026 | Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2
- [Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order
- [Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/legislation/si-no-403-of-2026.html) T1 · Retrieved · retrieved 1 Nov 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

- Coimisiún na Meán is designated an Irish AI Act market-surveillance authority for prohibited practices and transparency obligations in its regulated sector.Confidence: Probable · EvidencedEvidence and sources[Coimisiún na Meán](https://www.cnam.ie/industry-and-professionals/codes-legislation/legislation/eu-artificial-intelligence-act/) T1 · Retrieved · retrieved 1 Nov 2026Coimisiún na Meán is one of 15 Market Surveillance Authorities designated in Ireland to supervise compliance with the AI Act.

- Derived: Probable AI Act penalties are tiered up to EUR 35m/7% turnover for prohibited-practice breaches, EUR 15m/3% for other obligations, and EUR 7.5m/1% for misleading information, with a lower-of rule for SMEs.Confidence: Confirmed · EvidencedEvidence and sources[European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99) T1 · Retrieved · retrieved 1 Nov 2026 · s.136Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to EUR 35 000 000

- Derived: Probable Ireland caps administrative fines against public bodies for AI Act infringements at EUR 1,000,000.Confidence: Probable · As of 21 Jul 2026 · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/2026/act/31/section/136/enacted/en/html) T1 · Retrieved · retrieved 1 Nov 2026the amount of the fine shall not exceed €1,000,000.

- Derived: Probable National market surveillance authorities in Ireland apply EU-wide procedures to act against AI systems that present a risk, including corrective action, restriction, withdrawal or recall.Confidence: Probable · As of 2 Aug 2026 · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/isbc/2026_31.html) T1 · Retrieved · retrieved 1 Nov 2026 · Art 79Ss. 1-77 | 31 July 2026 | Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2

- Ireland's S.I. No. 366 of 2025 designates the Minister for Enterprise, Tourism and Employment as national competent authority, and the Central Bank of Ireland and Data Protection Commission among the market surveillance authorities under the AI Act.Confidence: Probable · EvidencedEvidence and sources[Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/what-we-do/innovation-research-development/artificial-intelligence/eu-ai-act/) T1 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 366 of 2025it provides exemptions for certain applications of AI relating to national defence; national security; scientific R&D; R&D for AI systems, models; open-sourced models; and personal use.
- [ai-act-law.eu](https://ai-act-law.eu/article/113/) T3 · Retrieved · retrieved 10 Nov 2026Articles 102 to 110 shall apply from 27 July 2026.
- [ISMS Copilot](https://www.ismscopilot.com/learn/eu-ai-act-what-applies-from-2-august-2026) T3 · Retrieved · retrieved 1 Nov 2026high-risk Chapter III Sections 1-3 are deferred by Regulation (EU) 2026/1744 to 2 December 2027 (Annex III) and 2 August 2028 (Annex I product route).

- Derived: Probable The Regulation of Artificial Intelligence Act 2026 (No. 31/2026) commenced on 31 July 2026, establishing the AI Office of Ireland, a single point of contact function, an AI regulatory sandbox and a domestic enforcement/penalty regime.Confidence: Probable · As of 31 Jul 2026 · EvidencedEvidence and sources[artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff
- [European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act-explorer) T1 · Retrieved · retrieved 1 Nov 2026 · s.1Article 22: Authorised representatives of providers of high-risk AI systems
- [European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99) T1 · Retrieved · retrieved 1 Nov 2026 · s.136Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to EUR 35 000 000
- [artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 403 of 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

- Coimisiún na Meán has been designated as one of Ireland's 15 market surveillance authorities for AI Act prohibited-practice and transparency obligations in the media sector.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[aiactblog.nl](https://www.aiactblog.nl/en/ai-act/bijlage/3) T3 · Surfaced · retrieved 1 Nov 2026 · S.I. No. 405 of 2026AI systems intended to be used for biometric categorisation, according to sensitive or protected attributes or characteristics based on the inference of those attributes or characteristics

- The Central Bank of Ireland is designated as Ireland's market surveillance authority under Article 74(6) of the AI Act for high-risk AI systems used by financial institutions.Confidence: Probable · As of 25 Jul 2025 · Carried forwardEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2025/si/366/made/en/print) T1 · Retrieved · retrieved 10 Nov 2026The Central Bank of Ireland is designated as the market surveillance authority for the purposes of Article 74(6).

- The Data Protection Commission is designated as Ireland's market surveillance authority under Article 74(8) of the AI Act for high-risk AI systems in law enforcement, migration, justice and specified biometric uses under Annex III.Confidence: Probable · As of 25 Jul 2025 · Carried forwardEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2025/si/366/made/en/print) T1 · Retrieved · retrieved 10 Nov 2026The Central Bank of Ireland is designated as the market surveillance authority for the purposes of Article 74(6).

- The AI Office of Ireland became operational on 1 August 2026 as Ireland's Article 70(2) single point of contact for the AI Act, superseding the interim ministerial designation.Confidence: Confirmed · As of 1 Aug 2026 · EvidencedEvidence and sources[AI Office of Ireland](https://aioffice.gov.ie/about-us/what-we-do/) T1 · Retrieved · retrieved 10 Nov 2026Now operational, the Office provides strategic governance in relation to the AI Act
- [imiel.dev](https://imiel.dev/explore/eu-ai-act-2026/ireland/) T3 · Retrieved · retrieved 10 Nov 2026Ireland's Regulation of AI Act 2026 commenced 31 July 2026, creating the AI Office of Ireland alongside 15 designated regulators

- Ireland established the AI Office of Ireland by statute, with functions to coordinate competent authorities, raise AI literacy, and advise the Minister, acting independently.Confidence: Probable · As of 21 Jul 2026 · EvidencedEvidence and sources[Irish Statute Book (Office of the Attorney General)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/print.html) T1 · Retrieved · retrieved 10 Nov 2026(1) The Office shall, in addition to the carrying out of other functions conferred on it by this Act or any other enactment— (a) coordinate the activities of relevant competent authorities to encourage consistent implementation and supervision of the Artificial Intelligence Regulation,

- Ireland designated 15 national competent authorities under Article 70(1) of the EU AI Act, later updated by S.I. 405/2026 to add the AI Office of Ireland.Confidence: Confirmed · As of 16 Sep 2025 · EvidencedEvidence and sources[Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/news-and-events/department-news/2025/september/20250916.html) T1 · Retrieved · retrieved 10 Nov 2026Speaking today, Minister for Enterprise, Tourism and Employment, Peter Burke, confirmed the designation of 15 National Competent Authorities under the AI Act.

- Irish market surveillance authorities must report annually to the AI Office and CCPC all Article 73 serious incidents of high-risk AI systems in the State.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order

### 11Sandboxes & Transitional ReliefActive Derived: Probable▾#

Regulation of Artificial Intelligence Act 2026 (Valid from 2026-07-31).

2 instruments (2 current) · 1 obligation · 10 claims · 1 milestone · Next: 2 Aug 2027 (EU-level AI regulatory sandbox operational deadline (deferred))

The Regulation of Artificial Intelligence Act 2026 (No. 31/2026), in force since 31 July 2026, empowers the AI Office of Ireland under section 46 to establish one or more national AI regulatory sandboxes pursuant to Article 57 of the EU AI Act, with the Data Protection Commission required to be involved where personal data is processed within a sandbox. Personal data originally collected for other purposes may be processed within a sandbox for the development, training or testing of AI, subject to that Data Protection Commission involvement. Sections 59 and 60 of the Act establish a separate real-world testing regime under which providers of Annex III high-risk AI systems may apply to the relevant market surveillance authority to test such systems in real-world conditions outside a sandbox, under Article 60 of the EU AI Act; permission is granted only where the Article 60(4) conditions are met.

The AI Office of Ireland is required to establish an AI regulatory sandbox, and the Digital Omnibus on AI has deferred that sandbox's EU-level operational deadline from 2 August 2026 to 2 August 2027. As of October 2026, the AI Office's sandbox programme remained under development, with no sandbox cohort yet announced.

Instruments (2)
- Regulation of Artificial Intelligence Act 2026 Valid from 2026-07-31Binding
- Regulation of Artificial Intelligence Act 2026 In force since 2026-07-31Binding

Obligations

- s.48Providers of Annex III high-risk AI systems may apply to the relevant market surveillance authority to conduct real-world testing outside a sandbox, per AI Act Article 60.Other · Applies to: Provider · Regulation of Artificial Intelligence Act 2026

Milestones

- 2 Aug 2027EU-level AI regulatory sandbox operational deadline (deferred) UpcomingRegulation of Artificial Intelligence Act 2026

Claims and evidence (10)
- As of October 2026 the AI Office's sandbox programme remained under development with no sandbox cohort yet announced.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 403 of 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

- Section 46 of the Regulation of Artificial Intelligence Act 2026 empowers the AI Office of Ireland to establish one or more national AI regulatory sandboxes under Article 57 of the AI Act, in force from 31 July 2026.Confidence: Probable · EvidencedEvidence and sources[Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order

- An applicant may apply to the relevant market surveillance authority to conduct real-world testing of a high-risk AI system outside a sandbox under ss.59-60 of the Act (Art 60 AI Act), with permission granted only where Art 60(4) conditions are met.Confidence: Probable (Capped from Confirmed: best source is T3) · EvidencedEvidence and sources[streamlex.eu](https://streamlex.eu/articles/aia-en-art-73/) T3 · Retrieved · retrieved 1 Nov 2026In November 2024, the Irish government published a refresh of its national AI strategy titled "Ireland's National AI Strategy: AI – Here for Good"

- Ireland's Regulation of Artificial Intelligence Act 2026 entered into force 31 July 2026, establishing the AI Office of Ireland, a sandbox, and an enforcement regime.Confidence: Probable · As of 31 Jul 2026 · EvidencedEvidence and sources[Irish Statute Book](https://www.irishstatutebook.ie/eli/isbc/2026_31.html) T1 · Retrieved · retrieved 1 Nov 2026 · Art 79Ss. 1-77 | 31 July 2026 | Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2
- [Irish Statute Book (eISB)](https://www.irishstatutebook.ie/eli/2026/act/31/enacted/en/pdf) T1 · Retrieved · retrieved 10 Nov 2026This Act shall come into operation on such day or days as the Minister may by order
- [Department of Enterprise, Tourism and Employment](https://enterprise.gov.ie/en/legislation/si-no-403-of-2026.html) T1 · Retrieved · retrieved 1 Nov 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

- Derived: Probable The Regulation of Artificial Intelligence Act 2026 (No. 31/2026) commenced on 31 July 2026, establishing the AI Office of Ireland, a single point of contact function, an AI regulatory sandbox and a domestic enforcement/penalty regime.Confidence: Probable · As of 31 Jul 2026 · EvidencedEvidence and sources[artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff
- [European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act-explorer) T1 · Retrieved · retrieved 1 Nov 2026 · s.1Article 22: Authorised representatives of providers of high-risk AI systems
- [European Commission (AI Act Service Desk)](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99) T1 · Retrieved · retrieved 1 Nov 2026 · s.136Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to EUR 35 000 000
- [artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 403 of 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

- Section 46 of the Regulation of Artificial Intelligence Act 2026 empowers the AI Office of Ireland to establish AI regulatory sandboxes, with Data Protection Commission involvement required where personal data is processed.Confidence: Probable (capped: best source is T3) · As of 31 Jul 2026 · EvidencedEvidence and sources[CMS DigitalLaws](https://www.cms-digitallaws.com/en/ai-act/article-6/) T3 · Retrieved · retrieved 1 Nov 2026 · s.46The Office may establish one or more AI regulatory sandboxes (in this Part referred to as a "sandbox") in accordance with Article 57.

- Sections 59-60 of the Regulation of Artificial Intelligence Act 2026 establish a real-world testing regime for high-risk AI systems outside the sandbox, subject to market surveillance authority permission.Confidence: Probable (capped: best source is T3) · As of 21 Jul 2026 · EvidencedEvidence and sources[aiactblog.nl](https://www.aiactblog.nl/en/ai-act/bijlage/3) T3 · Surfaced · retrieved 1 Nov 2026 · ss.59-60the relevant market surveillance authority may permit the applicant to conduct testing of the AI system in real world conditions

- Sections 48-50 of Ireland's Regulation of Artificial Intelligence Act 2026 let providers of high-risk AI systems apply to test them in real-world conditions outside a sandbox, under AI Act Article 60.Confidence: Confirmed · As of 31 Jul 2026 · EvidencedEvidence and sources[Houses of the Oireachtas](https://data.oireachtas.ie/ie/oireachtas/act/2026/31/eng/enacted/a3126.pdf) T1 · Retrieved · retrieved 10 Nov 2026Testing of high-risk AI systems in real world conditions in accordance with that Article, or

- Ireland's AI Office must establish an AI regulatory sandbox, with its operational deadline deferred from 2 August 2026 to 2 August 2027 by the EU Digital Omnibus on AI.Confidence: Confirmed · As of 8 Jul 2026 · EvidencedEvidence and sources[Oireachtas Library & Research Service](https://data.oireachtas.ie/ie/oireachtas/libraryResearch/2026/2026-07-08_bill-digest-regulation-of-artificial-intelligence-bill-2026_en.pdf) T1 · Retrieved · retrieved 10 Nov 2026sandbox is required to be operational by 2 August 2026.

- Ireland's AI Act allows personal data collected for other purposes to be processed in an AI sandbox for AI development/training/testing, with DPC involvement where personal data is processed.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Matheson](https://www.matheson.com/insights/irish-government-publishes-regulation-of-artificial-intelligence-bill-2026/) T3 · Retrieved · retrieved 10 Nov 2026personal data lawfully collected for other purposes may be processed within a sandbox environment

### 12Commercial ActivityActive▾#

As of October 2026 the AI Office's sandbox programme remained under development with no sandbox cohort yet announced.

0 instruments (0 current) · 0 obligations · 1 claim · 0 milestones

As of October 2026, the AI Office of Ireland's sandbox programme for AI-related commercial activity remained under development, with no sandbox cohort yet announced.

Cited evidence in this module rests solely on tier 3/4 commentary despite primary official sources existing for this jurisdiction.

Claims and evidence (1)
- As of October 2026 the AI Office's sandbox programme remained under development with no sandbox cohort yet announced.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[artificial-intelligence-act.com](https://www.artificial-intelligence-act.com/Artificial_Intelligence_Act_Article_4.html) T3 · Retrieved · retrieved 1 Nov 2026 · S.I. No. 403 of 2026This Order appoints 31 July 2026 as the day on which the Regulation of Artificial Intelligence Act 2026 (No 31 of 2026)

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## Authorities

Authority Type

AI Office of Ireland (Oifig IS na hÉireann) Ai office

Minister for Enterprise, Tourism and Employment Ministry

Central Bank of Ireland Market surveillance

Data Protection Commission Data protection authority

Coimisiún na Meán Market surveillance

[AI Office of Ireland (Oifig IS na hÉireann)](https://aioffice.gov.ie) Ai office

Central Bank of Ireland Market surveillance

Data Protection Commission Market surveillance

Coimisiún na Meán Market surveillance

## Enforcement actions

No enforcement actions recorded in this research.

## Cases

No cases recorded in this research.

## Consultations

No consultations recorded in this research.

What this record does not yet establish is set out on the [transparency register](/gaps/#gap-ie); its dated events are on the [regulatory calendar](/calendar/?jid=IE).

Think something on this page is wrong? [Report an error](/legal/#contact).

Technical provenance (record schema, run ID & build metadata) Schema version artificial-intelligence-record-v2.12 Research run ID aic-union-IE-2026-11-04 Page model module-card-page-v1 Renderer render_jid_aic_v13 Build date 12 Nov 2026