Is using Claude at work, or building on it, covered by the EU AI Act?

What applies to every use?

• Two things, whatever Claude is used for: the AI literacy duty and the prohibitions.
• Chapters I and II, which hold Articles 4 and 5, apply from 2 February 2025 (Article 113, third paragraph, point (a), as replaced by Regulation (EU) 2026/1744).
• That point keeps two later dates: Article 5(1), first subparagraph, points (ba) and (bb) apply from 2 December 2026, as do Article 5(1a) and (1b).

• Article 4(1), as replaced by Regulation (EU) 2026/1744: providers and deployers of AI systems take measures to support the development of AI literacy of their staff and of other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context of use, and considering the persons or groups of persons on whom the systems are to be used. The obligation does not require them to guarantee any specific level of AI literacy of any individual.
• Article 5(1), first subparagraph, point (f): placing on the market, putting into service for this specific purpose or using AI systems to infer the emotions of a natural person in the areas of workplace and education institutions is prohibited, except where the use is intended to be put in place or into the market for medical or safety reasons.

When does a Claude use become high-risk?

• When it is used for a purpose Annex III lists.
• Drafting, summarising, coding help and answering questions are not in it.
• Screening applicants, evaluating creditworthiness and evaluating students’ learning outcomes are, and the company that repurposes a general-purpose assistant that way can become the provider of a high-risk system.
• Chapter III, Sections 1, 2 and 3, which hold the high-risk requirements and the deployer duties of Article 26, apply from 2 December 2027 for systems classified as high-risk under Article 6(2) and Annex III, with the exception of Article 6(5) (Article 113, third paragraph, point (c), as replaced by Regulation (EU) 2026/1744).

• Point 4 of Annex III: AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyse and filter job applications and to evaluate candidates, and AI systems intended to be used to make decisions affecting terms of work-related relationships, the promotion or termination of work-related contractual relationships, to allocate tasks based on individual behaviour or personal traits or characteristics or to monitor and evaluate the performance and behaviour of persons in such relationships.
• Article 25(1), point (c): any distributor, importer, deployer or other third party that modifies the intended purpose of an AI system, including a general-purpose AI system, which has not been classified as high-risk and has already been placed on the market or put into service, in such a way that it becomes a high-risk AI system in accordance with Article 6, is considered a provider of a high-risk AI system and is subject to the provider obligations under Article 16.

What changes when you build on it?

• You become the provider of your own AI system, and its classification is yours to make.
• The provider of a general-purpose model owes you information under Article 53(1), point (b), unless Article 53(2) exempts it.
• Chapter V, which holds Article 53, applies from 2 August 2025 (Article 113, third paragraph, point (b)).
• Whether you are the deployer at all: am I a deployer if we just use ChatGPT at work?.

• Article 3, point (3): a provider is a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model or has one developed and places it on the market or puts the AI system into service under its own name or trademark, whether for payment or free of charge.
• Article 53(1), point (b): the provider of a general-purpose AI model draws up, keeps up to date and makes available information and documentation to providers of AI systems who intend to integrate the model, so that they can understand its capabilities and limitations and comply with their own obligations, containing at least the elements in Annex XII, without prejudice to the need to observe and protect intellectual property rights and confidential business information or trade secrets. Article 53(2) lifts that duty for a model released under a free and open-source licence that allows access, usage, modification and distribution, with its weights and the information on its architecture and usage made public, and never for a model with systemic risk.

What about the company that makes the tool?

• Whoever provides the AI system or the general-purpose AI model behind a tool carries the provider’s duties, and they are that provider’s own.
• This page says nothing about how any vendor meets them: nothing here was read from a vendor’s own terms, and the duties above are yours whatever those terms say.

Complipath itself sends some data to Anthropic’s API. Which data, on which paths, is listed on the subprocessors page.