Recommendation Engines under the EU AI Act: Your Compliance Guide

Recommendation engines are minimal risk unless they manipulate behaviour. Dark patterns and manipulative nudging violate the EU AI Act Article 5 and the Digital Services Act. Transparent, non-manipulative recs are safest.

Do you come under the EU AI Act?

The EU AI Act reaches any company whose AI output is used in the European Union — regardless of where the company is based. If your product has EU users or clients, the rules apply to you. The first question is always the same: which risk tier does your system fall into, and what duties come with that tier?

Which risk tier applies to you?

The Act sorts AI into four tiers: prohibited (banned outright), high-risk (heavy duties), limited-risk (transparency only), and minimal-risk (no mandatory duties). Most software starts in limited or minimal risk. The expensive surprises live in high-risk and prohibited — which is exactly why scanning early matters.