✓ Low compliance impact for SMEs
WHAT THE ARTICLE IS ABOUT
Integrating AI Act requirements into civil aviation security law
Article 102 is a legislative housekeeping article — one of a series in Chapter XIII that amends existing EU sectoral legislation to ensure coherence with the new AI Act. It amends the civil aviation security regulation to ensure that AI systems used in that sector are subject to AI Act requirements alongside existing aviation-specific rules.
WHAT IT SAYS
Civil aviation security regulation updated to reference AI Act requirements
- Regulation (EC) No 300/2008 on common rules in the field of civil aviation security is amended to include a reference to AI Act compliance requirements where AI systems are used in aviation security screening and related operations
- The amendment ensures that AI systems used for passenger screening, baggage inspection, access control, and similar aviation security functions must comply with both the sectoral aviation regulation and the AI Act
- Where AI systems are safety components of civil aviation products covered by Annex I of the AI Act, the sectoral conformity assessment procedure takes precedence and AI Act requirements are assessed as part of it
WHO IS AFFECTED
Civil aviation security operators and AI providers serving the aviation sector
- Airport operators and airlines using AI-based security screening systems
- Providers of AI systems designed for civil aviation security applications
- National aviation security authorities responsible for compliance oversight
- The European Aviation Safety Agency in its AI oversight coordination role
WHAT IT MEANS FOR SMES
Relevant only if you operate in civil aviation security
- This amendment has no practical relevance for the vast majority of SMEs
- If you provide AI systems for airport security, passenger screening, or civil aviation access control: your system is likely classified as high-risk under Annex II of the AI Act and this amendment ensures coherence between AI Act requirements and your existing sectoral compliance obligations
- Where you operate under existing civil aviation security certifications, check whether the AI systems embedded in your operations now require additional AI Act compliance steps
Related Articles
- Article 2 — Scope (how the AI Act applies to products subject to existing EU harmonisation legislation)
- Article 6 — High-risk classification (Annex I and Annex II products covered by this amendment)
- Article 43 — Conformity assessment (sectoral procedures take precedence for Annex I products)
- Article 113 — Entry into force (the application timeline for Chapter XIII provisions)
