AI Act vs PLD: what they share and how they differ
AI Act and PLD share 6 of 24 control themes and 8 checks. 100% of PLD requirements can be proven with checks AI Act already uses, 27% 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
PLD
Product liability: what changes for AI
4 requirementsNext Dec 9, 2026
6/24shared control themes
8shared checks
100%of PLD requirements covered by AI Act evidence
27%of AI Act requirements covered by PLD evidence
At a glance
| AI Act | PLD | |
|---|---|---|
| Jurisdiction | European Union same | European Union same |
| Kind | Regulation | Directive |
| Status | Phasing in | Adopted, not yet applicable |
| Binding | Yes same | Yes same |
| Object analysed | AI system | Digital product |
| Scope | Providers, deployers, importers and distributors of AI systems; providers of GPAI models. | Manufacturers, including those who substantially modify a product. |
| Territorial reach | Extraterritorial: applies when the system is placed on the EU market or its output is used in the EU. | Products placed on the EU market. |
| Penalties | Up to €35M or 7% of worldwide turnover (prohibited practices); €15M or 3% (other obligations); €7.5M or 1% (incorrect information). | Civil compensation, uncapped. |
| Qualification axes | AI Act risk level, Organisation role, General-purpose model | — |
| Roles | Provider, Deployer, GPAI provider | Manufacturer, Substantial modifier |
| Requirements | 33 | 4 |
| Next milestone | Aug 2, 2027, Annex I high risk (regulated products); GPAI placed on the market before Aug 2025 | Dec 9, 2026, Transposition and application to products placed on the market |
Theme by theme
requirements per theme
AI ActPLD
Governance
Assessment
Build
People & use
Lifecycle & third parties
What they share: one piece of evidence, two frameworks
8
| Code | Check | Requirements AI Act | Requirements PLD |
|---|---|---|---|
| VER-005-01 | Complete technical documentation compliant with Annex IV | ||
| VER-006-01 | Documented log retention policy | ||
| VER-009-02 | Accuracy and robustness verified and documented | ||
| VER-009-03 | Cybersecurity of the AI system verified | ||
| VER-011-01 | 10-year document retention policy documented and implemented | ||
| VER-021-F-01 | Operational monitoring plan | ||
| VER-026-F-01 | Contractual responsibilities documented between provider and third parties | ||
| VER-026-D-01 | Role qualification analysis (provider/deployer/distributor) carried out |
Differences: requirements specific to each framework
Requirements with no check serving the other framework: the extra work.
AI Act
24
EX-001
AI literacy Art. 4
EX-002
Prohibited practices Art. 5
EX-003
Risk management Art. 9
EX-004
Data and data governance Art. 10
EX-007
Transparency to deployers Art. 13
EX-008
Human oversight Art. 14
EX-010
QMS Art. 17
EX-013
Corrective actions Art. 20
EX-016
CE marking Art. 48
EX-017
EU database registration Art. 49
EX-018
Transparency for all systems Art. 50
EX-019
DPIA Art. 26§9
EX-020
FRIA Art. 27
EX-022
Serious incident reporting Art. 73
EX-023
Accessibility Art. 16(l)
EX-024
Conformity assessment Art. 43
EX-025
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
EX-033
PLD
0
None: every requirement shares at least one check.
Timelines
PastSet in the textPotentialTo verify
Apr 21, 2021AI Act · Commission proposal
Jul 12, 2024AI Act · Published in the Official Journal
Aug 1, 2024AI Act · Entry into force
Dec 8, 2024PLD · Entry into force
Feb 2, 2025AI Act · Prohibited practices (Art. 5) and AI literacy (Art. 4)
Feb 11, 2025PLD · AI Liability Directive withdrawal announced
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)
Dec 9, 2026PLD · Transposition and application to products placed on the market
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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