AI Act vs CoE Convention: what they share and how they differ
AI Act and CoE Convention share 7 of 24 control themes and 5 checks. 60% of CoE Convention requirements can be proven with checks AI Act already uses, 12% the other way round.
Phasing in
AI Act
How to make an AI system compliant with the EU AI Act
33 requirementsNext Aug 2, 2027
Adopted, not yet applicable
CoE Convention
What the Council of Europe AI Convention requires
5 requirementsNext 2027
7/24shared control themes
5shared checks
60%of CoE Convention requirements covered by AI Act evidence
12%of AI Act requirements covered by CoE Convention evidence
At a glance
| AI Act | CoE Convention | |
|---|---|---|
| Jurisdiction | European Union | Council of Europe |
| Kind | Regulation | Treaty |
| Status | Phasing in | Adopted, not yet applicable |
| Binding | Yes same | Yes same |
| Object analysed | AI system same | AI system same |
| Scope | Providers, deployers, importers and distributors of AI systems; providers of GPAI models. | Public authorities; private sector at each state's choice. |
| Territorial reach | Extraterritorial: applies when the system is placed on the EU market or its output is used in the EU. | State parties. |
| Penalties | Up to €35M or 7% of worldwide turnover (prohibited practices); €15M or 3% (other obligations); €7.5M or 1% (incorrect information). | Depends on national implementation. |
| Qualification axes | AI Act risk level, Organisation role, General-purpose model | Sector |
| Roles | Provider, Deployer, GPAI provider | Public authority, Private actor |
| Requirements | 33 | 5 |
| Next milestone | Aug 2, 2027, Annex I high risk (regulated products); GPAI placed on the market before Aug 2025 | 2027, Entry into force after 5 ratifications incl. 3 member states |
Theme by theme
requirements per theme
AI ActCoE Convention
Governance
Assessment
Build
People & use
Lifecycle & third parties
What they share: one piece of evidence, two frameworks
5
| Code | Check | Requirements AI Act | Requirements CoE Convention |
|---|---|---|---|
| VER-003-01 | Documented and up-to-date risk register | ||
| VER-018-D-01 | Persons informed of the interaction with an AI system | ||
| VER-018-D-03 | AI-generated content marked as such | ||
| VER-020-D-01 | FRIA carried out in accordance with Art. 27 | ||
| VER-033-D-01 | Decision explanation procedure documented |
Differences: requirements specific to each framework
Requirements with no check serving the other framework: the extra work.
AI Act
29
EX-001
AI literacy Art. 4
EX-002
Prohibited practices Art. 5
EX-004
Data and data governance Art. 10
EX-005
Technical documentation Art. 11 + Annexe IV
EX-006
Record-keeping / logging Art. 12
EX-007
Transparency to deployers Art. 13
EX-008
Human oversight Art. 14
EX-009
EX-010
QMS Art. 17
EX-011
10-year retention Art. 18
EX-012
Automatically generated logs Art. 19
EX-013
Corrective actions Art. 20
EX-014
Cooperation with authorities Art. 21 + Art. 26§12
EX-015
EU declaration of conformity Art. 47
EX-016
CE marking Art. 48
EX-017
EU database registration Art. 49
EX-019
DPIA Art. 26§9
EX-021
Post-market monitoring Art. 72
EX-022
Serious incident reporting Art. 73
EX-023
Accessibility Art. 16(l)
EX-024
Conformity assessment Art. 43
EX-025
EX-026
Value chain Art. 25
EX-027
Compliant use Art. 26§1
EX-028
Input data Art. 26§4
EX-029
Information to affected persons Art. 26§11
EX-030
Information to workers' representatives Art. 26§7
EX-031
GPAI obligations Art. 53
EX-032
CoE Convention
2
COE-10
Equality and non-discrimination Art. 10
COE-11
Privacy and data protection Art. 11
Timelines
PastSet in the textPotentialTo verify
Apr 21, 2021AI Act · Commission proposal
May 17, 2024CoE Convention · Adopted by the Committee of Ministers
Jul 12, 2024AI Act · Published in the Official Journal
Aug 1, 2024AI Act · Entry into force
Sep 5, 2024CoE Convention · Opened for signature (Vilnius)
Nov 28, 2024CoE Convention · HUDERIA methodology adopted
Feb 2, 2025AI Act · Prohibited practices (Art. 5) and AI literacy (Art. 4)
Jul 10, 2025AI Act · GPAI Code of Practice published
Aug 2, 2025AI Act · GPAI obligations, governance, penalties, notified bodies
Nov 19, 2025AI Act · Digital Omnibus proposal: high-risk delay tied to standards
Aug 2, 2026AI Act · General application: Art. 50, sandboxes, Annex III high risk (unless Omnibus delay)
2027CoE Convention · Entry into force after 5 ratifications incl. 3 member states
Aug 2, 2027AI Act · Annex I high risk (regulated products); GPAI placed on the market before Aug 2025
Dec 2, 2027AI Act · Omnibus backstop for Annex III high risk
Aug 2, 2028AI Act · Omnibus backstop for Annex I high risk
Aug 2, 2030AI Act · High-risk systems of public authorities already in service (Art. 111)
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