EU AI Act: New rules take effect in Northern Ireland

On 10 November 2026, the new EU AI Act was added to the Windsor Framework, and some of its rules took effect in Northern Ireland. Guidance published by the Department for Business, Innovation, Science and Trade on 4 November 2026 explains that their scope is much narrower than in the EU. The guidance sets out what manufacturers, importers and distributors of physical products containing AI need to do to prepare.

Key points

1. Physical products only. The rules apply only where an AI system is "closely integrated" with a physical product sold in Northern Ireland. This generally means the AI is built in at the point of sale, or the product is designed to depend on separately downloaded AI to work as intended.
2. Software is largely out of scope. Standalone AI tools, apps and online chatbots are generally not covered. Businesses that simply use AI tools in their work are not affected.
3. The rules cover selling, not use. The bans on prohibited AI cover putting products on the market, not using them. Users of high-risk AI only have to report risks and serious incidents.

Phased timetable

The rules take effect in stages. Some rules already in force across the EU only now begin to apply in Northern Ireland. All the rules will apply by 2028:

• 10 November 2026 - Three sets of rules take effect:

1. Bans on prohibited AI apply to in-scope products containing banned AI practices, such as manipulative techniques or emotion detection in the workplace.
2. AI literacy duties require providers to help staff and others who operate their AI systems understand them in a way suited to their role.
3. Users must be told they are interacting with AI where this is not obvious, for example with an interactive toy for young children.

• 2 December 2026 - The bans on generating non-consensual intimate images and child sexual abuse material take effect. AI-generated audio, images, video and text must also carry machine-readable markers, for example a smart speaker that produces AI voice responses.
• 2 December 2027 - Rules on high-risk uses take effect. They cover products used in areas such as biometrics, critical infrastructure, education and worker management, for example a warehouse wearable that scores worker productivity.
• 2 August 2028 - Rules take effect for AI that performs a safety function in regulated products such as toys, lifts and medical devices, where those products need independent assessment.

Practical implications

Businesses should check whether their products are in scope and identify which rules apply. They should expect in-scope products with prohibited AI already on sale to be withdrawn. Manufacturers should prepare for the high-risk rules and get technical information from their AI suppliers.

For further information, you can access the guidance here: Guidance and the EU AI act in Nothern Ireland.