Artificial intelligence is becoming a business necessity. Understanding its legal implications is now a corporate responsibility.

As artificial intelligence becomes increasingly integrated into business operations, organisations across Greece and the European Union face a changing regulatory environment. From customer service and recruitment to financial analysis, marketing and operational decision-making, AI is transforming how companies operate, compete and grow.

The European Union’s Artificial Intelligence Act (EU AI Act), Regulation (EU) 2024/1689, establishes a comprehensive legal framework governing the development, deployment and use of artificial intelligence.

For businesses operating in Greece, compliance is not simply a matter of adopting new policies. It requires understanding how AI is used throughout the organisation, identifying applicable legal obligations and establishing governance mechanisms that protect both commercial interests and regulatory accountability.

With important provisions already applicable in 2026 and further requirements scheduled for 2027 and 2028, businesses should assess their AI practices and establish a proportionate compliance strategy.

What Is the EU AI Act and Does It Apply to Businesses in Greece?

The EU AI Act is the European Union’s regulatory framework for artificial intelligence. It introduces a risk-based approach, with legal obligations determined by the nature of an AI system, its intended purpose and the role of the organisation involved.

As an EU Regulation, the AI Act is directly applicable in Greece, subject to its phased application dates and the relevant national arrangements for supervision and enforcement.

Importantly, the legislation does not apply exclusively to technology companies developing AI products.

Businesses that purchase, integrate or use AI systems in their daily operations may also fall within its scope.

This includes organisations using artificial intelligence for:

• Employee recruitment and assessment

• Customer interactions and automated communications

• Financial analysis and creditworthiness assessments

• Business forecasting and decision support

• Marketing and AI-generated content

• Operational management and process automation

• Data analysis and customer profiling

The applicable requirements depend on the specific system, its intended use and the organisation’s regulatory role. Not every business application of AI is classified as high-risk.

EU AI Act Compliance Deadlines: What Applies in 2026?

The EU AI Act is being implemented progressively, with different provisions becoming applicable at different stages.

Following the amendments introduced through the EU’s AI simplification measures in July 2026, the implementation timetable includes several important milestones.

2 February 2025: Prohibited AI practices and initial AI literacy provisions

The first restrictions on certain unacceptable AI practices became applicable. The AI literacy framework was also introduced, with subsequent amendments simplifying the approach to promoting AI literacy.

2 August 2025: General-purpose AI requirements

Rules governing providers of general-purpose AI models and relevant governance arrangements became applicable, subject to transitional provisions.

2 August 2026: Transparency requirements and wider enforcement

Article 50 transparency obligations became applicable to specified AI systems and uses, including certain interactive AI applications and AI-generated or manipulated content. Enforcement of applicable provisions also commenced.

2 December 2026: Additional prohibitions and transitional requirements

Further restrictions concerning certain non-consensual intimate content and child sexual abuse material take effect. A transitional deadline also applies to specified existing systems under Article 50(2).

2 December 2027: High-risk AI systems under Annex III

Requirements for AI systems classified as high-risk in specified areas, including employment, education and certain financial services applications, become applicable.

2 August 2028: High-risk AI integrated into regulated products

Requirements become applicable to specified AI systems connected with products regulated under the EU legislation listed in Annex I.

These different application dates make it essential for businesses to distinguish between obligations already in force and those requiring preparation for future compliance.

Which AI Systems Are Considered High-Risk?

One of the most important aspects of AI Act compliance is determining whether an organisation uses systems classified as high-risk.

The AI Act identifies certain applications that may create significant risks to health, safety or fundamental rights.

Examples include specified AI applications involving:

• Recruitment, employment and worker management

• Education and vocational training

• Access to certain essential private and public services

• Creditworthiness assessments of natural persons, subject to statutory exceptions

• Biometric identification and categorisation in specified circumstances

• Critical infrastructure management

• Certain law enforcement, migration and judicial applications

Classification is not determined solely by whether a system uses advanced technology.

It depends on its intended purpose, the circumstances of deployment and the criteria established by the Regulation.

A business using an AI-powered customer support tool may face different obligations from an organisation using AI to assess job applicants or determine individuals’ eligibility for financial services.

A documented legal classification is therefore an essential starting point for effective AI governance.

What Are the Responsibilities of Businesses Using AI?

The EU AI Act distinguishes between different operators, including providers, deployers, importers and distributors.

For many businesses, the relevant role will be that of a deployer, meaning an organisation using an AI system under its authority in a professional context.

However, a company that develops, substantially modifies or markets certain AI systems may assume additional responsibilities, potentially including those of a provider.

Depending on the classification and use of the system, relevant obligations may involve:

• Appropriate human oversight

• Use of AI systems in accordance with applicable instructions

• Monitoring system performance and identifying risks

• Maintaining relevant records and documentation

• Implementing transparency measures

• Establishing procedures for incidents and corrective action

• Assessing fundamental rights impacts where required

• Cooperating with competent regulatory authorities

Not every obligation applies to every AI system. The legal assessment must consider the organisation’s actual activities and the applicable regulatory provisions.

Why AI Governance Matters Beyond Regulatory Compliance

Effective AI governance is not limited to avoiding administrative penalties.

It can also protect commercially sensitive information, strengthen contractual relationships, support internal accountability and reduce the risks associated with unreliable or inappropriate AI outputs.

For example, an organisation may adopt a generative AI application to improve employee productivity without establishing clear rules concerning confidential information, personal data or intellectual property.

Another business may rely on an external AI vendor without adequately assessing contractual responsibilities, security arrangements or liability for system failures.

These issues may arise independently of whether an AI system is classified as high-risk under the AI Act.

A comprehensive governance framework should therefore address the wider legal environment, including:

Data Protection and GDPR

Assessing the lawful processing of personal data, transparency, security and relevant data protection obligations.

Intellectual Property

Reviewing AI-generated content, third-party rights, licensing arrangements and the protection of proprietary business information.

Employment Law

Establishing appropriate safeguards for AI applications affecting employees, recruitment and workplace decisions.

Commercial Contracts

Evaluating AI procurement arrangements, vendor responsibilities, warranties, indemnities and liability allocation.

Cybersecurity and Confidentiality

Addressing security vulnerabilities, confidential business information and the interaction between AI systems and existing corporate infrastructure.

AI governance should form part of the organisation’s broader legal, risk management and compliance strategy.

How Can Businesses Prepare for EU AI Act Compliance?

For organisations operating in Greece, preparation should begin with a structured assessment of existing AI use rather than the immediate adoption of generic compliance templates.

A practical approach involves five stages.

1. Identify AI Systems Across the Organisation

Businesses should establish which AI applications are being used, by whom and for what purpose.

This includes externally procured systems, internally developed tools and generative AI applications adopted by individual departments.

2. Determine Regulatory Roles and Risk Classifications

Each system should be assessed to determine the organisation’s role and whether the application falls within a prohibited, high-risk, transparency-related or other relevant category.

The legal reasoning supporting that assessment should be documented.

3. Establish Internal AI Governance Policies

Organisations should develop proportionate policies addressing acceptable AI use, accountability, approvals, data protection, confidentiality, human oversight and incident reporting.

4. Review Contracts and Regulatory Documentation

AI vendor agreements, procurement arrangements, relevant notices and compliance records should be reviewed against applicable legal requirements.

5. Implement Ongoing Monitoring

AI governance should be maintained as an ongoing process.

Changes in technology, business use, contractual arrangements or applicable regulation may require reassessment of existing systems and internal procedures.

The Business Value of a Structured AI Compliance Strategy

For companies investing in artificial intelligence, regulatory compliance and commercial performance should not be treated as competing objectives.

A well-designed AI governance framework can support both.

By establishing clear responsibilities and documented procedures, organisations can make better-informed decisions about AI procurement, reduce uncertainty around implementation and identify legal risks before they develop into operational or regulatory problems.

Structured governance can also strengthen confidence among customers, commercial partners, investors and other stakeholders.

For businesses seeking to expand AI adoption, the objective is not simply to demonstrate compliance at a particular point in time.

It is to create a sustainable framework that enables innovation while maintaining appropriate legal oversight.

EU AI Act Compliance in Greece: Frequently Asked Questions

Does the EU AI Act apply to all companies in Greece?

The AI Act may apply to businesses developing, providing, importing, distributing or using AI systems within its scope. However, the specific obligations depend on the organisation’s role, the system’s classification and its intended use.

Is using ChatGPT or another generative AI tool automatically considered high-risk?

No. The use of a generative AI tool does not automatically make an organisation’s activity high-risk. Classification depends on the particular application, intended purpose and relevant legal criteria. Other obligations, including transparency, data protection and confidentiality, may still be relevant.

When do the EU AI Act’s high-risk requirements apply?

Following the 2026 amendments, the principal high-risk requirements are scheduled to apply from 2 December 2027 for Annex III systems and 2 August 2028 for relevant systems connected with regulated products under Annex I, subject to applicable transitional rules.

Do businesses need an AI governance policy?

The AI Act does not impose an identical standalone governance-policy requirement on every business using AI. Nevertheless, internal policies can help organisations implement applicable obligations, allocate responsibilities and manage associated legal and commercial risks.

Can a company be responsible for AI supplied by an external vendor?

Yes. Depending on its regulatory role and use of the system, a business may have responsibilities even when the technology has been developed by a third-party provider. Contractual arrangements do not automatically eliminate statutory obligations.

Moving from AI Adoption to Legal Readiness

As artificial intelligence becomes an increasingly important component of business operations, organisations must ensure that innovation is supported by appropriate legal structures.

The EU AI Act introduces a new regulatory framework, but effective AI governance requires a broader assessment of business activities, contractual relationships, operational risks and existing legal obligations.

Early identification of AI systems, accurate regulatory classification and structured governance can help businesses prepare for future requirements while addressing obligations already in force.

Legal readiness should enable responsible AI adoption, not delay it.

For organisations seeking to assess their regulatory position, AI Discovery & Mapping provides a practical starting point for identifying systems, evaluating applicable requirements and establishing compliance priorities.

Explore our Corporate AI Readiness & EU AI Act Compliance services.