Glossary · EU AI Act: machinery and Annex I
Transitional presumption of conformity (Machinery Regulation Art. 20(10))
Also known as: Article 20(10) Machinery Regulation, AI Act standards bridge
Article 20(10) of the Machinery Regulation, added by Regulation (EU) 2026/1744, is a transitional rule: as long as no machinery-specific harmonized standards or common specifications cover the AI-related requirements, a presumption of conformity can be drawn from the harmonized standards or common specifications of the AI Act that cover them.
- AI regulation
- EU
- Machinery
- Omnibus
In one sentence
Machinery Regulation Art. 20(10) lets AI Act harmonized standards support presumption of conformity until machinery-specific standards exist.
Example
A packaging machine builder applies a cited AI Act harmonized standard on robustness to its AI-based reject detection and lists it in the technical file as the basis for the presumption for that requirement.
How it applies
- Source, not date: The rule changes where the presumption of conformity can come from. It does not move the machinery examination to 2028 and does not make the full AI Act framework apply to machinery in 2027.
- Temporary: It applies until machinery-specific harmonized standards or common specifications are referenced or adopted under the Machinery Regulation.
- Limited: As with any presumption, it covers only the requirements the AI Act standard actually addresses, and only standards whose references are cited. AI Act harmonized standards were still being developed by CEN and CENELEC JTC 21 when this entry was reviewed.
- Technical documentation: Name each standard, its edition and the requirement it is used for, and state that the presumption rests on Article 20(10).
Compared with the USA, Canada and China
There is no presumption of conformity in US or Canadian law; standards support a manufacturer's defense and regulators' expectations rather than creating a legal presumption. China's system of mandatory and recommended GB standards works differently again: mandatory standards must be met, recommended ones are voluntary.
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