Does the EU AI Act apply to AI agents?
The AI Act's articles and annexes never use the word "agent". It regulates "AI systems", and most AI agents may fit that definition. What applies depends on what the agent does, not on what it is called. The Act also reaches companies outside the EU when their agent's output is used in the EU.
The definition
Article 3(1): "‘AI system’ means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments;"
An agent that reads a request, decides what to do and acts may fit this text.
Who it reaches
- Providers, "irrespective of whether those providers are established or located within the Union or in a third country" (Art. 2(1)(a)).
- Deployers in the EU (Art. 2(1)(b)).
- Providers and deployers outside the EU, "where the output produced by the AI system is used in the Union" (Art. 2(1)(c)).
If you build the agent, you are usually its provider. If you run it for your own work, you are its deployer (Art. 3(3) and 3(4)).
What may apply, by agent type
| Agent | Parts that may apply | From |
|---|---|---|
| Support or sales agent that chats with people | Article 50(1): people must be told they are dealing with AI, unless it is obvious. The Article 5 bans. | 2 August 2026; bans since 2 February 2025 |
| Voice agent on calls | Article 50(1). Article 5(1)(f) if it infers the emotions of staff at work. | 2 August 2026; 2 February 2025 |
| Meeting or workplace copilot | Article 5(1)(f) if it infers emotions at work. Annex III, point 4(b), if it is used to "monitor and evaluate the performance and behaviour" of staff. | 2 February 2025; 2 December 2027 |
| Hiring or HR agent | Annex III, point 4(a): "to analyse and filter job applications, and to evaluate candidates" | 2 December 2027 |
| Browsing or computer-use agent | Article 50(1) when it deals directly with people for you. The Article 5 bans. | 2 August 2026; 2 February 2025 |
| Coding agent | The Article 5 bans, as for every AI system. Annex III point 4 is unlikely unless it ranks or monitors staff. | 2 February 2025 |
Where Astroware fits: HaloGuard EU, part of EU Mode, is built to block AI output the EU AI Act bans or treats as high-risk, such as inferring workers' emotions from their face, voice or body, and output that hides that it is AI.
Sources:
- Regulation (EU) 2024/1689, Articles 2, 3, 5 and 50, and Annex III: http://data.europa.eu/eli/reg/2024/1689/oj
- Regulation (EU) 2026/1744 for the dates: http://data.europa.eu/eli/reg/2026/1744/oj
As of 28 October 2026. This page explains the text of the Act. It is not legal advice.