ARXO-2026-0427 · Reported
AI Act: which event starts the 10-year period of Articles 18(1) and 22(3)(b) when placing on the market and putting into service fall on different dates?
Articles 18(1) and 22(3)(b) count 10 years after the high-risk AI system has been placed on the market or put into service. Where the two events happen on different dates, the text does not say which one starts the period.
Consequence
Where the two events fall on different dates, the end of the 10-year period differs by the interval between them.
Proposed correction
The guidelines could say which event starts the period.
- Jurisdiction
- European Union — European Union
- Act
- Regulation (EU) 2024/1689 (Artificial Intelligence Act)
- Place
- Articles 18(1) and 22(3)(b)
- Record
- Question of reading or data
- Class
- Question of reading or data
- Where it arose
- The text of the act
- Arxo's conclusion
- Confirmed
- Official text
- Unchanged at last check
- Last checked
- 2026-10-31
Evidence
Reproduced by execution. Quotations are verbatim from the official material; translations are ours and marked.
after the high-risk AI system has been placed on the market or put into service
How to check it without Arxo's tools
- Open Regulation (EU) 2024/1689 (Artificial Intelligence Act), Official Journal, 12 July 2024, English version and find Article 18(1) (English). Compare the text with the quotation above. A copy is kept in this register: 8f0b656302f9864c-en.xhtml (SHA-256
8f0b656302f9864cc87e040c371f209a9d65ae1a6cecc25ca5eb737e872d721a, copy of the official file). - The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.
How this finding was made
AI models helped read and compare the texts and review the draft letters. AI models also helped build the illustrative rule models.
Responsible institutions
- European Commission, European AI Office — applies the Regulation and prepares the Commission's guidelines
Reported to
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-31 | European Commission, European AI Office | Message-ID: <CAH-SH70YM_AC_01zvysJGHJc08uAX6NxnU6XtfyeJT2hGLo=Gw@mail.gmail.com> |
Responses
No response recorded.
History
- 2026-10-31Confirmed by Arxo
- 2026-10-31Entered in the register
- 2026-10-31Reported to European Commission, European AI Office (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0427, https://arxo.io/findings/ARXO-2026-0427/ (status as of 2026-10-31). Data: ARXO-2026-0427.json.