AI Act & E-Signatures: Compliance Requirements for EU Businesses 2026

The EU Artificial Intelligence Act (Regulation (EU) 2024/1689) entered into force on 1 August 2024, establishing the world's first comprehensive horizontal legal framework for regulating AI systems across all 27 EU Member States.

Key Legislative Objectives:

• Ensure AI systems placed on European markets are safe and respect fundamental rights
• Establish harmonised rules for AI development, deployment, and use throughout the EU
• Create predictable regulatory environment fostering innovation whilst protecting citizens
• Position Europe as global leader in trustworthy artificial intelligence

The European Commission, working closely with the newly established EU AI Office, oversees implementation and enforcement. Market surveillance authorities in each Member State monitor compliance and investigate violations.

Electronic signature platforms increasingly incorporate AI capabilities across multiple operational areas:

Common AI Applications in E-Signature Services:

• Automatic document analysis: AI identifies signature fields, form elements, and required data points
• Fraud detection systems: Machine learning algorithms detect suspicious signing patterns and potential identity fraud
• Workflow automation: AI routes documents based on content analysis and business rules
• Identity verification: Biometric authentication and facial recognition for signer verification
• Contract intelligence: Natural language processing extracts key terms and obligations
• Risk assessment: AI evaluates transaction risk levels and suggests appropriate authentication methods

At Yousign, we're actively assessing how our platform's intelligent features align with AI Act requirements, ensuring our customers benefit from automation whilst maintaining full regulatory compliance.

For businesses implementing GDPR-compliant electronic signatures, the AI Act creates additional compliance layers requiring coordinated data protection and AI governance approaches.

The AI Act's provisions apply gradually through staggered deadlines rather than taking immediate effect. Understanding this phased implementation is crucial for compliance planning.

Specific bans on manipulative AI, social scoring, and remote biometrics take effect alongside mandatory AI literacy training for all employees. The Commission published detailed guidelines on prohibited AI practices to clarify interpretation.

The European AI Office and national authorities assume full oversight, enforcing new transparency and documentation mandates for General-Purpose AI providers. GPAI models must comply with copyright policies and technical documentation requirements.

Full compliance becomes mandatory for most high-risk AI systems (listed in Annex III), requiring established quality management, human oversight, and formal registration in the EU database. Providers must complete conformity assessments and obtain CE marking before placing their systems on the market.

The deadline extends for AI embedded as safety components in regulated products (like medical devices) and for General-Purpose AI models that were already on the market before August 2025. This grace period supports legacy system transitions.

The AI Act adopts risk-based regulatory approaches, linking compliance obligations to specific risks AI systems pose. This classification determines which requirements apply to your e-signature platform.

• Unacceptable Risk (Prohibited): These systems are strictly banned because they threaten fundamental rights through practices like social scoring or subliminal manipulation. They cannot be developed or deployed within the EU under any circumstances. Violations trigger the highest penalties.
• High-Risk AI: This category covers systems used in critical areas like employment, education, and essential infrastructure. Such tools must undergo rigorous conformity assessments and maintain detailed technical documentation to ensure safety and oversight. Annex III lists specific high-risk use cases.
• Limited Risk: Systems like chatbots or deepfake generators must meet specific transparency requirements to ensure users are aware they are interacting with AI. This tier focuses on preventing deception through clear disclosure mandates.
• Minimal Risk: The majority of AI applications, such as spam filters or AI-enabled video games, fall into this category and face no specific obligations under the Act. While unregulated, providers are still encouraged to follow voluntary codes of practice.

Most standard e-signature functionality falls into minimal or limited-risk categories. However, certain advanced features may qualify as high-risk:

Potentially High-Risk E-Signature AI Functions:

• Biometric authentication systems
• Employment contract systems
• Credit assessment integration
• Essential services access

AI governance frameworks must evaluate each feature independently. A single platform may contain multiple AI systems at different risk levels, each requiring separate classification and compliance measures.

The AI Act distinguishes between "providers" (developing or substantially modifying AI systems) and "deployers" (using AI systems in professional contexts), imposing different obligations on each.

Organisations developing high-risk AI systems face comprehensive compliance requirements:

Providers must maintain a detailed technical file that describes the system's architecture, algorithmic logic, and risk mitigation measures to prove compliance before market entry. Documentation must be accessible to market surveillance authorities and the AI Office upon request.

High-risk systems must undergo a formal assessment—either through internal quality controls or third-party audits—to secure a CE marking and an official EU Declaration of Conformity. Notified bodies conduct independent evaluations for certain high-risk categories.

Companies are required to implement post-market monitoring systems to track real-world performance and must immediately report serious incidents or malfunctions to regulatory authorities. Providers must maintain logs and update risk assessments continuously.

Organisations using high-risk AI systems developed by third parties must:

• Use systems according to instructions provided by developers
• Assign human oversight responsibilities to appropriately trained personnel
• Monitor system functioning and report incidents to providers
• Maintain logs automatically generated by high-risk systems
• Conduct data protection impact assessments where required under GDPR

Deployers must also ensure appropriate AI literacy among staff operating high-risk systems, implementing mandatory training programs by 2 February 2025.

General-purpose AI models—systems performing wide ranges of distinct tasks like large language models—face specific regulatory requirements since August 2025.

All GPAI model providers must:

• Create and maintain comprehensive technical documentation
• Provide detailed summaries of training data content
• Implement policies ensuring EU copyright and intellectual property law compliance
• Make documentation available to AI Office, national regulators, and downstream users

The Commission published a Code of Practice for GPAI providers, offering standardized approaches to meet these obligations.

Particularly powerful GPAI models classified as having "high impact capabilities" (based on computing power, range, or potential impact) face enhanced obligations:

• Report system details to European Commission
• Conduct structured evaluation and testing procedures
• Permanently document security incidents
• Implement enhanced cybersecurity measures
• Assess and mitigate systemic risk

Classification Criteria:

Models demonstrating cumulative computing power exceeding 10^25 floating point operations (FLOPs) or designated by Commission as having capabilities presenting systemic risks.

The AI Act establishes substantial financial penalties for violations, structured according to infringement severity. Market surveillance authorities enforce these penalties across all Member States.

Penalty Tiers:

Beyond financial penalties, non-compliance risks include:

• Reputational damage affecting customer trust
• Product removal orders from EU market
• Potential civil liability for damages caused
• Criminal sanctions under national laws

The Commission emphasizes proportionate enforcement, considering company size, violation severity, and cooperation during investigations. However, penalties for prohibited practices remain severe regardless of organization size.

Identify and document every AI system within your organization to classify them by risk tier and determine your regulatory status for each tool. Map all features using machine learning, neural networks, or algorithmic decision-making.

Define whether you are a provider, deployer, or both to establish clear accountability and manage legal obligations with your suppliers. Document responsibility matrices for each AI system.

Compile the required technical files for high-risk systems, transparency disclosures for limited-risk tools, and copyright policies for GPAI integrations. Begin drafting conformity assessment documentation now.

Appoint dedicated compliance officers and cross-functional committees to implement standardized approval workflows for all AI capabilities. Create clear escalation paths for risk classification disputes.

Launch mandatory AI literacy programs to ensure all staff and contractors understand their specific regulatory obligations. Training must cover prohibited practices, risk identification, and incident reporting by 2 February 2025.

Establish a systematic audit process to track evolving technical standards and ensure continued compliance as the legal landscape matures. Schedule quarterly reviews of AI system classifications and governance procedures.

E-signature businesses must navigate AI Act compliance alongside existing regulatory frameworks:

eIDAS Regulation Coordination:

The AI Act complements rather than replaces eIDAS requirements. Businesses must ensure:

• AI-powered identity verification meets both eIDAS authentication standards and AI Act transparency requirements
• Audit trails capture both eIDAS-required signing events and AI Act-mandated decision logging
• Qualified electronic signatures maintain compliance whilst incorporating AI enhancements

For detailed guidance on eIDAS compliance and signature levels, understanding how simple, advanced, and qualified signatures interact with AI capabilities becomes essential.

AI systems processing personal data trigger overlapping GDPR and AI Act obligations:

• Data minimisation principles apply to AI training data
• Impact assessments may need to address both GDPR and AI Act requirements
• Transparency obligations span both regulations
• Subject rights extend to AI-driven decisions

Organizations must coordinate governance structures across GDPR, eIDAS, and AI Act frameworks to avoid duplicative processes whilst ensuring comprehensive compliance.

The EU AI Act marks a shift toward mandatory AI governance, making compliance a core competitive advantage for e-signature providers. To maintain market trust and avoid penalties, businesses should:

• Audit Early: Create an inventory of all AI-integrated systems to determine risk levels and identify high-risk features requiring immediate attention.
• Implement Governance: Establish clear accountability structures and update product roadmaps to include regulatory requirements. Appoint dedicated compliance officers with authority to pause deployments.
• Prioritize Literacy: Train staff to manage the intersection of AI automation and legal compliance. Mandatory training programs must be operational by 2 February 2025.
• Coordinate Regulations: Build unified governance frameworks addressing AI Act, GDPR, and eIDAS simultaneously. Avoid siloed compliance approaches that create gaps and inefficiencies.

By balancing innovation with these new regulatory standards, firms can leverage AI efficiencies while ensuring long-term sustainability in the European market. The European Commission and AI Office provide ongoing guidance and support tools to facilitate compliance.