EU AI Act Article 105: Marine Equipment Directive Amendment

✓ Low compliance impact for SMEs

WHAT THE ARTICLE IS ABOUT

AI Act integrated into marine equipment regulation

Article 105 amends the marine equipment directive to ensure that AI systems used in shipboard safety equipment are subject to the AI Act’s requirements in addition to existing maritime safety rules. As AI systems increasingly appear in navigation, collision avoidance, and safety monitoring on commercial and passenger vessels, this integration ensures a coherent governance framework.

WHAT IT SAYS

Marine equipment directive updated to reference AI Act compliance

Directive 2014/90/EU on marine equipment is amended to include reference to AI Act requirements for AI systems used in marine equipment
Where AI systems form part of marine equipment subject to the directive, AI Act compliance is assessed as part of the marine equipment approval process
The amendment ensures market surveillance for marine equipment extends to AI Act compliance monitoring

WHO IS AFFECTED

Marine equipment manufacturers and maritime AI providers

Manufacturers of shipboard safety equipment incorporating AI — navigation systems, collision avoidance, monitoring systems
AI providers developing systems for maritime applications
Flag state administrations and classification societies involved in marine equipment approval

WHAT IT MEANS FOR SMES

Relevant only for maritime sector AI providers

No direct relevance for most SMEs outside the maritime equipment sector
If you develop AI systems for shipboard safety, navigation assistance, or maritime monitoring: check whether your product falls within the marine equipment directive and requires AI Act compliance as part of that process
The maritime sector has well-established international safety standards — AI Act integration adds an EU-specific layer on top of IMO and flag state requirements

Article 104 — Two-wheel vehicle amendment (preceding amendment in the series)
Article 106 — Railway amendment (following amendment)
Article 6 — High-risk classification (Annex I products)
Article 43 — Conformity assessment (sectoral procedures take precedence)

Article 105 – Amendment to Directive 2014/90/EU