By use case · Written by Yobel Tzegai · Last checked 9 October 2026

Is emotion recognition allowed under the EU AI Act?

Emotion recognition under the EU AI Act: prohibited at work and in education except for medical or safety reasons, high-risk elsewhere, disclosed always.

Check your AI systems, freeBook a 30-minute walkthrough

The answer, in detail

Where an emotion recognition use sits, and from when
UseOutcomeProvisionApplies from
Inferring employees’ or students’ emotionsProhibited, except for medical or safety reasonsArticle 5(1), first subparagraph, point (f)2 February 2025, under Article 113, third paragraph, point (a), as replaced
Emotion recognition on customers or the publicHigh-riskPoint 1(c) of Annex III2 December 2027, under Article 113, third paragraph, point (c), as replaced
Informing the people exposedA deployer dutyArticle 50(3)2 August 2026, under Article 113, second paragraph; the later date in Article 111(4) is for Article 50(2) alone
Sentiment read from textNot an emotion recognition systemArticle 3, point (39), which requires biometric dataWhether point (f) reaches it at work is not settled by the text

What counts as emotion recognition?

Where is it prohibited?

What does a deployer owe elsewhere?

Your customer asks. You answer with proof.

  1. 1List every AI system

    Add the AI you use. Each system gets a role, a risk class and the article it rests on.

    Live
  2. 2Attach the proof

    Link each duty to a file and the page it stands on: a policy, a log setting, a training record.

    Live
  3. 3Answer their questionnaire

    Answering a customer's questionnaire inside the app, from the proof you already linked.

    Coming soon

What Complipath does

  • Risk classification Answers go through rules in code, never a language model, so the same answers always give the same result. Rules decide. AI only drafts. A person confirms.
  • AI inventory Every AI system you build or use, with its owner and risk class
  • Obligations per system Confirming a classification creates the obligations that follow from it, each with an owner, a status and a place for evidence
  • Deadlines Each obligation carries the date it applies from, derived from where the provision sits rather than written onto the row

Rules decide. AI only drafts. A person confirms.

What it does not do yet

  • Customer questionnaires (audit room) Coming soon Coming soon: answering a customer's AI questionnaire from your own register.
  • Domain-specific guidance Not supported Guidance written for one sector.

What is live today

Checked against the app on 8 October 2026
Starter

€499 a month

Prices exclude VAT.

  • Up to 20 AI systems
  • Every duty, deadline and article
  • Evidence and the audit log
  • Your first system is free, with no end date
Check your AI systems, free

All plans

Questions

Is a fatigue or stress monitor at work prohibited?

Not if it is intended for medical or safety reasons, the exception in Article 5(1), first subparagraph, point (f). Without that purpose, inferring a worker’s emotions at the workplace is prohibited. Whether fatigue or stress counts as an emotion is not settled by the text of the Act, and this page does not settle it.

Can we use emotion recognition on customers?

Outside the workplace and education, it is not prohibited by point (f). It is high-risk under point 1(c) of Annex III, in so far as its use is permitted under relevant Union or national law, and Article 50(3) has the deployer inform the people exposed and process their data under the GDPR.

Read next
See what your customers will ask about your AI.No account needed. Every answer cites the article it rests on.