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Machinery with AI: what the Machinery Regulation requires for self-evolving behaviour

Not every piece of “AI” software turns a machine into high-risk machinery. What matters is whether a learning system ensures safety functions – then procedure and requirements change.

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In brief

  • Annex I Part A covers safety components and embedded systems with fully or partially self-evolving behaviour using machine learning that ensure safety functions – always with a notified body.
  • Software that does not learn and only executes programmed functions is not covered (recital 55).
  • Annex III requires such control systems to stay within their task and movement space, to record safety-related decisions and to be correctable at any time (1.2.1).
  • The risk assessment covers foreseeable hazards from the evolution of behaviour (Annex III Part B, point 1).
Annex I Part A points 5, 6Annex III 1.2.1Annex III 1.1.6Recitals 54, 55

When Annex I Part A applies

Two categories concern learning systems: point 5 safety components with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions; point 6 machinery with such embedded systems not placed on the market separately – only in respect of those systems. A notified body is mandatory for both (Art. 25(2)).

Where machinery embeds a system whose safety components were already assessed by a third party when placed on the market separately, the machinery need not be recertified for that reason alone (recital 54).

What Annex III requires of learning control systems

RequirementContentReference
LimitsThe control system must not cause the machine to act beyond its defined task and movement space1.2.1, 2nd para. (a)
RecordingData on the safety-related decision-making process are recorded and kept for one year for the authorities1.2.1, 2nd para. (b)
CorrectionThe machine must be correctable at any time to maintain its inherent safety1.2.1, 2nd para. (c)
Learning phaseChanges to settings or rules, including during the learning phase, are prevented where they could be hazardous1.2.1, 1st para. (d)
TraceabilityInterventions and uploaded versions of safety software remain traceable for up to five years1.2.1, 1st para. (f)
InteractionAdapt the interface to the foreseeable characteristics of operators; where appropriate communicate planned actions understandably1.1.6(f), (g)

In the risk assessment

The assessment covers hazards that may arise during the life cycle and are foreseeable at placing on the market because the behaviour or logic evolves by design (Annex III Part B, point 1). The limits of safety functions are defined in the risk assessment (1.2.1, 1st para. (d)). On reasoned request, source code or programming logic must be made available to the authority (Art. 10(3)).

And the AI Act?

The AI Act, Regulation (EU) 2024/1689, classifies as high-risk AI systems that are safety components of products covered by the harmonisation legislation in its Annex I. With the Digital Omnibus on AI, given final approval by the Council on 29 June 2026 (Regulation (EU) 2026/1744), the Machinery Regulation is, according to available summaries, moved within that annex: AI in machinery would then be governed mainly through the Machinery Regulation, which the Commission may supplement by delegated acts; obligations for such high-risk systems would apply from 2 August 2028. Check the text published in the Official Journal before basing your planning on it.

Frequently asked questions

Is a machine with machine vision automatically Part A?

No. Part A only applies where a system with self-evolving behaviour through machine learning ensures safety functions. A quality-inspection AI without a safety function is not covered.

What about a model trained once that does not learn in operation?

Recital 55 excludes software that is neither capable of learning nor of evolving. For the specific model, this must be justified technically and documented; in case of doubt, clarify with a notified body.

Does the recording obligation apply to every machine?

The one-year recording concerns control systems with self-evolving behaviour designed for varying levels of autonomy. Five-year traceability of interventions and software versions applies to control systems in general (1.2.1).

Document learning systems traceably

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Read next

Sources. Regulation (EU) 2023/1230, OJ L 165, 29.6.2023, including the corrigendum of 1.4.2025; Directive 2006/42/EC for the previous regime. On the Digital Omnibus on AI: summaries by specialist law firms (October 2026); only the Official Journal text is authentic.

The information has been checked against the official text, paraphrased and shortened; only the official text is authentic.

normakte is a drafting and calculation aid; it replaces neither conformity assessment, nor a notified body, nor a technical assessment by a specialist, nor legal advice.

Further reading: other topics of the Machinery Regulation