The EU released on 5 March 2025 updated model clauses on AI procurement to align with the AI Act. The model clauses were developed within the Community of Practice on Public Procurement of AI, which is supported by the European Commission. It should be noted however that the model clauses state that they are working documents and do not reflect an official position of the European Commission.
The newly updated clauses include:
- a full version for high-risk AI systems, aligned with the AI Act’s latest provisions;
- a light version, offering customizable terms for non-high-risk AI systems; and
- a commentary, providing guidance on implementation and adaptation for specific use cases.
The full version focuses on areas outlined under Chapter III of the AI Act for high-risk AI systems such as risk management, transparency, human oversight, data governance, and compliance audits.
The light version, which is primarily aimed at AI systems not designated as high risk pursuant to the AI Act, focuses on transparency obligations, basic risk management, limited data governance and optional clauses that can be tailored based on risk level.
The model clauses and the commentary can be found here.
