Article 90 of Regulation (EU) 2024/1689 — Alerts of systemic risks by the scientific panel. Official text, practical interpretation, key obligations and compliance implications.
Article 90 wires an alarm bell straight from science to enforcement: the scientific panel of independent experts can formally alert the AI Office when it suspects a systemic risk — or a model that should have been designated and was not.
Official Text Summary
The scientific panel of independent experts established under Article 68 may provide a qualified alert to the AI Office where it has reason to suspect that a general-purpose AI model poses a concrete identifiable risk at Union level, or that a model meets the conditions for classification as a model with systemic risk under Article 51 without having been so classified. Upon such a qualified alert, the Commission, through the AI Office and after informing the Board, may exercise the powers of Section 5 — requesting documentation and information under Article 91, conducting evaluations under Article 92 and requesting measures under Article 93. The provider concerned is kept informed. The mechanism turns independent scientific expertise into a formal enforcement trigger rather than background advice.
Key Obligations
- The scientific panel may issue a qualified alert where it has reason to suspect a concrete identifiable risk at Union level from a GPAI model, or that a model meets the Article 51 systemic-risk conditions without having been classified
- Upon a qualified alert, the Commission, through the AI Office, may exercise the Section 5 powers — documentation requests, evaluations, measures
- The provider concerned is informed; the alert mechanism makes independent science a formal enforcement trigger, not just advice
Compliance Timeline
Applies from 2 August 2026; the 2026 Digital Omnibus deferred the substantive high-risk obligations (Annex III to 2 December 2027, Annex I to 2 August 2028) but did not move this provision.
Official AI Act Compliance Deadline Calendar
Updated · Sources: Regulation (EU) 2024/1689 and the 2026 Digital Omnibus on AI.
| Obligation | Applies to | Original date | New date | Status | Countdown | Legal basis |
|---|---|---|---|---|---|---|
| Prohibited Practices (Art. 5) | All providers and deployers | active | — | AI Act Art. 5 | ||
| GPAI Rules (Chapter 5) | GPAI model providers | active | — | AI Act Art. 51-56 | ||
| Commission Enforcement Powers over GPAI | GPAI model providers | active | — | AI Act Art. 88-94, 101 | ||
| Transparency Obligations (Art. 50) | Providers and deployers of chatbots, generative, emotion recognition systems | active | — | AI Act Art. 50 | ||
| New Art. 5 Prohibition (CSAM / non-consensual intimate imagery) | Providers and deployers of generative AI systems | active | — | AI Omnibus 2026 Art. 5 | ||
| AI-Generated Content Marking (pre-existing systems) | Providers of generative AI systems on the market before 2 Aug 2026 | active | — | AI Act Art. 50(2) — transitional | ||
| Regulatory Sandboxes | National competent authorities | deferred | — | AI Omnibus 2026 Art. 57 | ||
| High-risk AI — Annex III (standalone) | Providers of standalone Annex III systems | deferred | — | AI Omnibus 2026 Art. 6(2) | ||
| High-risk AI — Annex I (embedded) | AI embedded in Annex I regulated products | deferred | — | AI Omnibus 2026 Art. 6(1) |
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AI Act meets DORA and NIS2
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Independent experts selected by the Commission under Article 68 for up-to-date scientific or technical expertise in AI, acting objectively and free of conflicts of interest. They advise the AI Office and the Member States — and Article 90 gives their concerns direct legal effect.
It can open the whole Section 5 ladder without any prior compliance failure: an alert can trigger a documentation request, then an evaluation, then a request for measures. Providers close to the Article 51 thresholds should treat panel signals as seriously as regulator letters.
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