Compliance
AI Act Compliance (EU AI Regulation 2024)
Term from the vending glossary
The EU AI Regulation (Regulation (EU) 2024/1689, effective from 1 August 2024) classifies AI systems into four risk classes and requires manufacturers and operators of intelligent vending machines to demonstrate tiered compliance, which becomes fully effective between February 2025 and August 2027. For the vending industry, the most relevant areas are age verification systems via camera analysis, biometric access control, and AI-driven personalisation.
Risk Classes and Vending Practice
The Regulation divides AI applications into four risk classes. Three of these are relevant to vending operators:
Prohibited (Art. 5, from 2 February 2025): Real-time facial recognition on publicly accessible machines in public spaces is prohibited, unless narrow exceptions for law enforcement purposes apply. Camera systems that merely count pedestrian flows without identifying individuals do not fall under this prohibition.
High-Risk (Annex III, from 2 August 2026): Systems for biometric age estimation on tobacco or alcohol machines fall into this category. Obligations: CE marking, technical documentation, and independent conformity assessment. The compliance effort for SMEs is estimated by the EU Commission at €6,000 to €10,000 solely for technical documentation (Source: EC Impact Assessment SWD(2021) 84).
Minimal Risk (no special obligations): AI-driven stock optimisation, dynamic pricing algorithms, and predictive maintenance systems are not subject to special requirements, provided no personal data are processed.
Operator Obligations
As a 'Deployer' (Art. 3 No. 4 AI Act), operators bear their own due diligence obligations once a high-risk system is deployed. The machine manufacturer should provide written confirmation of which AI components are installed and to which risk class they are assigned. If this information is not provided after 2 August 2026, fines up to €15 million or 3 per cent of global annual turnover are possible, whichever is higher.