Tier is everything. The distance between a limited-risk transparency duty and an Annex III high-risk conformity programme is roughly two orders of magnitude. Confirm your classification before you budget โ€” that single decision moves the number more than every other input on this page combined.

โ€”
first-year programme cost
โ€”ongoing per year
โ€”per system, year one
โ€”max fine exposure

Where the hours go

First-system effort by obligation workstream, plus the recurring annual duty each one leaves behind. Additional systems are charged at the reuse discount you set above, because a quality management system written once serves the whole portfolio.

WorkstreamArticleHours (1st system)Year-one costRecurring / yr

What each tier costs on your inputs

The same organisation, the same rate, the same number of systems โ€” priced at every tier. This is the table to look at before you accept someone's casual classification of your product.

TierYear oneOngoing / yr3-year totalFine band
โš ๏ธ Planning estimate, not legal advice. Hour ranges are modelled from the obligation set in Regulation (EU) 2024/1689 (Arts. 9โ€“15 risk management, data governance, technical documentation, record-keeping, transparency, human oversight, accuracy/robustness/cybersecurity; Art. 17 quality management system; Arts. 43โ€“48 conformity assessment and CE marking; Art. 72 post-market monitoring; Arts. 53โ€“55 GPAI). Actual effort varies widely with system complexity, existing ISO 42001 or ISO 27001 coverage, and whether a notified body is involved. Article 113 application dates and ongoing simplification amendments should be confirmed for your tier before you commit a budget. ยท Report an error โ†’

Why nobody will give you a number

Search for the cost of EU AI Act compliance and you get two kinds of answer: consultancies quoting six-figure ranges with no method, and law firms explaining the obligations without ever converting them into hours. Neither helps you write a budget line. The obligations are, however, unusually enumerable โ€” the Regulation lists them by article, and each one maps to a recognisable engineering or governance workstream. A risk management system under Article 9 is a documented, iterative process with owners and review cycles. Data governance under Article 10 is provenance, representativeness and bias examination on your training, validation and test sets. Article 11 technical documentation is a specified deliverable with an annex telling you what goes in it. Article 17's quality management system is the single largest line for most organisations and the one that scales best across a portfolio, which is why the reuse percentage above moves the total so much.

The tier decision dominates everything else

Run the tier comparison table and the shape is immediately obvious: limited-risk transparency duties are a rounding error, Annex III high-risk is a real programme, and Annex I high-risk adds a notified body whose fees you do not control. General-purpose model providers sit in their own regime under Article 53 โ€” model documentation, a copyright policy, and a sufficiently detailed public summary of training content โ€” with a second, much heavier layer at Article 55 for models presenting systemic risk, where adversarial evaluation and serious-incident reporting become continuous obligations rather than one-off deliverables. Most disputes about compliance cost are actually disputes about classification wearing a budget costume. Settle the tier first.

Compliance cost versus the thing it insures against

Article 99 caps penalties as the higher of a fixed amount or a share of worldwide turnover: 35 million euro or 7% for prohibited practices, 15 million or 3% for most other breaches including the high-risk requirements, and 7.5 million or 1% for supplying incorrect information. The percentage limb only overtakes the fixed limb above roughly 500 million euro of turnover, so for a mid-sized company the fixed ceiling is what matters and the ratio of exposure to programme cost is usually somewhere between 50ร— and 200ร—. That ratio is the argument, and it is worth putting in front of a finance team in exactly those terms. Once you have the programme scoped, price the systems it governs with the AI guardrails stack cost calculator and the LLM observability cost calculator โ€” logging and monitoring obligations under Articles 12 and 72 are met with infrastructure you also have to pay for.

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