For most of the run-up to enforcement, the mental model was a regulator with finite attention. You reasoned about your odds of being noticed. That model is now out of date. The Commission published three public intake tools on 31 July 2026. From 2 August 2026 the EU AI Act's enforcement powers apply, and the Commission has said plainly that it is enforcing the rules from that date. Outsiders and insiders can start a case through those published channels without waiting for an authority to notice first.
The three intake routes have different filers, different legal bases, and different anonymity. Getting them mixed up is the most common error in the early coverage, so it is worth separating them cleanly. Article 85 is the statutory right to complain to a market surveillance authority. Separately, the AI Office operates Commission tools for systems and GPAI models in its own enforcement remit. Those tools are not substitutes for each other.
Three ways a case now starts
| Channel | Who files | Basis and scope |
|---|---|---|
| Complaint (Article 85) | Any natural or legal person with grounds to consider there has been an infringement (Article 85). Not a personal-harm threshold. | Article 85 is a right to complain to the relevant market surveillance authority; those complaints are taken into account under Regulation (EU) 2019/1020. Separately, the Commission runs an AI Act complaints tool for alleged infringements by providers or deployers of AI systems under the AI Office's exclusive competence. That form is not anonymous (identification required) and is not for Arts 53–55 / Art 89(2) GPAI downstream complaints. |
| Whistleblower (Article 87) | Individuals professionally connected to providers of GPAI models or of AI systems in the AI Office's enforcement remit. Anonymous via a secure inbox; follow-up while remaining anonymous. | Article 87 applies Directive (EU) 2019/1937 to reporting AI Act infringements and protecting reporting persons. Commission tool: AI Act Whistleblower Tool (anonymous, encrypted channel; not the same form as the Art 85 complaints tool). |
| Downstream provider (Article 89(2)) | A downstream provider of an AI system built on another provider's GPAI model. Identified; not anonymous. | Article 89(2) gives downstream providers a right to lodge a duly reasoned complaint. The Commission's dedicated channel is scoped to alleged infringements of Articles 53 to 55 by GPAI model providers (technical documentation, information to downstream providers, copyright policy, training-data summary, and related GPAI / systemic-risk duties). Channel: downstream-provider complaints. |
The common thread is that detection is no longer only something that happens from above. A person or company closest to your system can start a case through a published channel, without waiting for a regulator to notice first.
An honest note on the temperature: as of the date of this post, no enforcement action and no complaint volumes have been publicly reported. There is no wave to point at yet. This is a readiness argument, not a panic one. The change that matters is structural: standing to lodge a complaint is no longer limited to authorities acting on their own initiative.
The question a complaint actually asks
When a market surveillance authority picks up a complaint, the question it puts to you is narrow and evidentiary. Not "are you a responsible company." It is closer to: for the specific interaction being complained about, show what your AI decided, on what basis, and when. A policy PDF does not answer that. A dashboard screenshot does not answer that. A log line that says flagged with no article attached does not answer it either.
The GDPR experience is a useful parallel, not a perfect identity. Complaint volume there did not mostly produce headline fines; it produced a tooling market for answering the request quickly. Companies bought the ability to respond, because the cost of a case is the scramble, not only the penalty. The EU AI Act creates analogous pressure: the tooling that answers it is a runtime evidence layer, not another policy document.
Hollow record versus complete record
Here is the distinction an authority cares about, made concrete. Two systems can both claim "we log everything." Only one produces a record that resolves a case.
| A hollow record | A complete record |
|---|---|
| "Event flagged." A severity or a risk score. No article. No binding to the specific input. No way to reproduce the decision. | A decision bound to the input by a hash, timestamped, attributed to an agent, carrying the rule identifier and the verbatim article the decision rests on, and linked in a tamper-evident chain so a single altered field breaks verification. |
That second column is what ComplyEdge aims to produce when a case needs a complete answer. On every check, as the decision happens, each record binds to the input as a SHA-256 hash (never the raw text), carries jurisdiction and engine path, and is linked in a tamper-evident chain; when a rule fires, the record also carries the rule identifier and the operative text of the article applied. The trail is exportable as a single verifiable artifact, generated as a by-product of enforcement rather than assembled in a scramble afterwards. For high-risk AI systems, Article 12 separately requires automatic logging capabilities that support traceability, post-market monitoring, and deployer monitoring under Article 26(5). Under Regulation (EU) 2026/1744 those Annex III high-risk Chapter III duties (including Art. 12) apply from 2 December 2027, not from August 2026. ComplyEdge's export is tooling aimed at that evidentiary demand, not a claim that the Act already mandates CE's specific field list for every system today.
Two boundaries, so this stays accurate in front of counsel. The AI Act does not mandate hashing, tamper-evidence, or any specific field list for these logs; that is a matter of producing a record you can stand behind when authorities ask questions. Article 99(5) makes the supply of incorrect, incomplete or misleading information to notified bodies or national competent authorities in reply to a request subject to administrative fines (up to €7.5M or 1% of worldwide annual turnover, whichever is higher). And ComplyEdge is the enforcement and evidence layer. It does not adjudicate the complaint, and it is not a substitute for counsel handling the case. It is what makes the evidence producible in days rather than weeks.
The downstream-provider angle nobody is covering
The third channel is the one most likely to be missed. If you build on a third party's general-purpose AI model, Article 89(2) gives you standing to lodge a duly reasoned complaint with the Commission. The dedicated Commission channel is limited to alleged infringements of Articles 53 to 55 by GPAI model providers. The flip side is the useful question for your own readiness: the Article 53(1)(b) information and documentation your upstream provider must make available so you can understand the model's capabilities and limitations and meet your own obligations, does it actually satisfy what you are entitled to. That is an obligation-mapping exercise, and it is exactly the kind of thing an article-cited record makes legible: you can show which obligations your own system covers, and point precisely at the seam where the upstream provider's duties begin.
What to do before the first case, not during it
- Assume the filer is not only a regulator. Under Article 85 it may be any natural or legal person with grounds to consider there has been an infringement; under Article 87 it may be a professionally connected insider filing anonymously.
- Decide now what you would hand over for a single disputed decision, and check whether you can actually produce it today.
- Make the record article-cited when a rule fires. "We blocked it" is weaker than "we blocked it under Article 5(1)(c), here is the entry."
- Keep the evidence retained and verifiable. For deployers of high-risk AI systems, Article 26(6) requires keeping automatically generated logs under their control for at least six months (unless other Union or national law provides otherwise). That floor binds with the Annex III high-risk package from 2 December 2027. ComplyEdge keeps records for 180 days, then expires them, as a product default today; Enterprise tenants can set a longer period.
None of this is about being virtuous before an audience that is not watching yet. It is about being the company that, when the first case does print, already has the answer in a form an authority can read. You can inspect the enforcement corpus and the audit-export format in the open:
pip install complyedgeRepository: github.com/ComplyEdge/complyedge
Deployer obligations, mapped to the mechanism: Article 26 one-pager
The related argument on agents and Article 50: the runtime enforcement audit trail