Guide · Updated 13 October 2026

The EU AI Act for Irish small businesses: what you actually need to do

A plain guide to the EU AI Act for Irish SMEs after the 2026 changes: AI literacy, telling people about AI, banned uses, and the new high-risk dates.

The EU AI Act is the EU's law on artificial intelligence. Most small businesses are users of AI tools, not makers, and for them the duties are light. The Act was amended in 2026 by the Digital Omnibus (Regulation (EU) 2026/1744, in force since 27 July 2026), which pushed back the high-risk rules.

This is a plain summary for owners, not legal advice. If you build AI products or use AI for decisions about people, get specialist advice.

At a glance
Banned uses
In force since 2 February 2025
AI literacy
Since 2 February 2025; rewritten in 2026 as a duty to take measures that support staff AI literacy
Telling people about AI
From 2 August 2026, for chatbots and AI-generated content
High-risk rules
Delayed to 2 December 2027 (and 2 August 2028 for AI built into regulated products)

What applies to a typical small business

  • AI literacy: take measures to support the AI literacy of staff who use AI for you, in proportion to how you use it. After the 2026 change this is an effort-based duty; you do not have to guarantee a set level for each person.
  • Transparency: if customers chat with an AI, or you publish AI-generated images, audio or video that could pass as real, make that clear.
  • Banned uses: do not use AI for the practices the Act prohibits, such as manipulating people or social scoring.

What changed in 2026

  • The Digital Omnibus on AI entered into force on 27 July 2026.
  • High-risk obligations for uses such as hiring, credit and education moved from August 2026 to 2 December 2027; AI built into products covered by EU product safety law moved to 2 August 2028.
  • Article 4 on AI literacy was rewritten, not removed: providers and deployers must take measures to support AI literacy, and the Commission and Member States must help, with particular attention to SMEs.

Are you using AI in a high-risk way?

Probably not, but check. Using AI to screen job applicants, decide on credit, or assess students are examples of high-risk uses. If you do any of these, the stricter rules will apply from December 2027 and you should get advice now.

A five-point checklist

  1. List the AI tools the business uses and what each is used for.
  2. Write a one-page AI policy: what data can go in, and that a person checks what goes out.
  3. Give staff short, practical AI training, and keep a note of it.
  4. Make it clear when customers are dealing with an AI, for example on a website chat.
  5. Check that none of your uses are high-risk; if any are, get advice before December 2027.

How AppAdvisor helps

Jack Connaughton follows the EU AI Act closely for our clients. We help Irish SMEs choose and use AI sensibly, write a simple AI policy, and train teams, as part of our AI advisory work and, where a business qualifies, through Digital for Business.

Questions

Does the EU AI Act apply to small businesses?

Yes, but lightly for most. A business that uses AI tools must take measures to support staff AI literacy, be open with people when they deal with an AI, and avoid banned uses. The heavier rules apply to high-risk uses and to AI makers.

Was the EU AI Act delayed?

Partly. The 2026 Digital Omnibus moved the high-risk rules to 2 December 2027 (2 August 2028 for AI in regulated products). Banned uses and AI literacy have applied since February 2025, and transparency duties from August 2026.

What is AI literacy under the AI Act?

Since the 2026 change, it is a duty to take measures that support the AI literacy of people using AI on your behalf, in proportion to the use. Short practical training and a simple AI policy are a sensible way to show it.

More questions answered
Sources, checked 13 October 2026

Schemes change. Always confirm the current terms with your Local Enterprise Office before you apply.

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