Is AI in logistics and warehousing covered by the EU AI Act?

When is warehouse management AI high-risk?

• When it decides who does what by behaviour or traits, or watches how people work.
• 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 26(7): before putting into service or using a high-risk AI system at the workplace, a deployer that is an employer informs the workers’ representatives and the affected workers that they will be subject to it, where applicable under the rules and procedures of Union and national law and practice on informing workers.

What about robots and vehicles?

• A warehouse robot, a forklift or a vehicle can reach the Act as a product, through Article 6(1), not through Annex III. Both conditions must hold: the AI system is a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I, and that product is required to undergo a third-party conformity assessment under that legislation.
• Regulation (EU) 2026/1744 moved the machinery regulation, Regulation (EU) 2023/1230, from Section A to Section B of Annex I (point 41), where motor vehicles already were.
• For AI systems classified as high-risk under Article 6(1) related to products covered by Section B, only Article 6(1), Article 60a and Articles 102 to 112 apply, with Articles 57, 58 and 59 only in so far as the requirements for high-risk AI systems have been integrated in that legislation (Article 2(2), as replaced by point 2).
• Article 6(1a) and (1b), inserted by point 8, say that an AI system solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control is not a safety component, and that one whose failure or malfunctioning would endanger health and safety is.
• That route needs its own assessment, and the free check does not decide it.

What applies to every use?

• Article 4 on AI literacy, and the prohibitions, including emotion inference at the workplace.
• 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.