# What the EU AI Act Actually Means for Your Library (Spoiler: More Than You Think) **Date:** 2026-01-15 **Category:** AI Regulation **Read Time:** 8 minutes Look, I get it. You\'re a librarian, not a lawyer. The last thing you want to read is another 500-page regulation document written by people who\'ve clearly never set foot in a library. But here\'s the thing: the EU AI Act became law in August 2024, with enforcement rolling out in phases. Prohibited AI systems were banned starting February 2, 2025, and the majority of provisions take full effect on August 2, 2026. If you're using AI tools - or even thinking about it - you need to understand what this means. And no, this isn\'t just "Europe\'s problem." Keep reading. ## The Quick Version (Because You're Busy) The EU AI Act is comprehensive AI regulation that categorizes AI systems by risk level. High-risk systems face stricter requirements than lower-risk or minimal-risk systems. For libraries, this may matter because: - Your vendor's AI tools might be subject to these rules - If you serve European patrons, you may be in scope - Other countries are adopting similar frameworks (Colorado, California, etc.) - Vendor compliance costs may affect pricing This is educational analysis only and not legal advice. Specific applicability depends on technical details and jurisdictional analysis that require legal counsel review. ## Why Should You Care If You're in Ohio? Fair question. Three reasons: **First**, global vendors aren\'t building two versions of their products - one for Europe, one for everywhere else. That\'s expensive and annoying. So they're building to EU standards and selling that version worldwide. Your next software update? Probably EU AI Act compliant, whether you asked for it or not. **Second**, if your library serves *any* European users (international students, researchers accessing your digital collections, etc.), you're technically in scope. That database vendor you use? They\'re sweating about this. **Third**, the U.S. is already copying this playbook. Colorado passed the Colorado AI Act in May 2024 (originally scheduled for February 2026, delayed to June 30, 2026), which directly mirrors the EU approach. California, New York, and several other states passed similar laws in 2025. This isn't going away. ## The Risk Pyramid (And Where Library AI Sits) The EU AI Act divides AI systems into four categories: ### Unacceptable Risk (Banned) Things like social scoring systems, manipulative AI, real-time facial recognition in public spaces. You're probably not touching this stuff. If you are... we need to talk. ### High-Risk This is where it gets interesting for libraries. High-risk systems include AI that: - Makes decisions about access to essential services (like... library services?) - Evaluates people (think: AI-driven program recommendations, resource access decisions) - Manages employment (if you're using AI in hiring) If your AI system is high-risk, you need: - Proper risk management processes - High-quality training data (no biased datasets) - Human oversight requirements - Transparency (users must know they're interacting with AI) - Detailed documentation **Important note:** Whether specific library AI tools are classified as high-risk under the EU AI Act depends on detailed technical and contextual analysis. Consult legal counsel familiar with the regulation to assess your specific systems. ### Limited Risk AI with transparency obligations. Chatbots, AI content generators, deepfakes. Users must be told they're interacting with AI. If you're running an AI research assistant chatbot? You need a disclosure. "This is an AI system" level stuff. Simple, but required. ### Minimal Risk Everything else. Video games, spam filters, basic recommendation systems. No specific requirements, but general EU law still applies (GDPR, accessibility rules, etc.). ## What This Means for Your Vendor Contracts Here's where you need to pay attention. When you sign that next database contract or discovery system agreement, look for: **1. AI Disclosure Clauses** Vendors should tell you if they\'re using AI, what it does, and how it works. If they\'re vague about this, that's a red flag. The EU AI Act requires transparency, and good vendors are getting ahead of it. **2. Data Usage Rights** High-risk AI systems need quality training data. If your vendor is training AI on library usage patterns, patron behavior, or circulation data - that's your data. You should know about it. And you should have veto rights. **3. Compliance Responsibility** Who\'s on the hook if the AI screws up? Under the EU AI Act, it\'s usually the "deployer" (that\'s you) and the "provider" (that\'s your vendor). Make sure your contract specifies who handles compliance work. **4. Algorithm Audits** High-risk systems need regular audits. If your vendor is subject to this, they'll pass costs along. Budget for it. And ask: Can you see the audit results? ## The British Library Ransomware Wake-Up Call Speaking of vendors and AI... remember when the British Library got hit with ransomware in October 2023? That wasn't AI-related, but it exposed something crucial: libraries are *terrible* at vendor security audits. The attack shut down the British Library for months. Catalog offline. Digital collections inaccessible. Millions in damages. Now imagine that happening because your AI vendor had a security hole. Or used biased training data. Or violated GDPR because they didn't understand EU AI Act compliance. The point: You can't just trust vendors to handle this. You need to ask questions. ## Questions to Ask Your Vendors When evaluating AI tools, consider asking vendors: 1. "Does this system use AI? If so, what does it do?" 2. "What data sources does this AI use for training or operation?" 3. "What documentation or compliance assessments do you have for this system?" 4. "Under what circumstances is this system subject to EU AI Act, Colorado AI Act, or similar regulations?" 5. "How are compliance responsibilities allocated in our contract?" 6. "Can we disable or opt out of AI features if needed?" 7. "What's your timeline for addressing emerging AI regulations?" Vendor responses should be clear enough to inform your risk assessment and legal compliance strategy. If responses are unclear, consult legal counsel before proceeding. ## What You Should Consider **Immediate steps:** - Consult with legal counsel about AI regulation compliance for your jurisdiction(s) and operations - Inventory systems you use that involve AI (discovery, chatbots, recommendation engines, cataloging) - Review vendor contracts for AI-related clauses and responsibility allocation - Document vendor responses about AI capabilities and compliance **Medium term (6-12 months):** - Work with legal counsel to develop AI tool evaluation criteria - Update procurement processes to include AI impact and compliance questions - Document your governance approach to AI tool decisions **Longer term:** - Monitor evolving regulations and vendor compliance statements - Review vendor offerings as compliance requirements become clearer - Consider patron communication about AI use in library systems This is educational analysis. For specific guidance about your compliance obligations, consult qualified legal counsel familiar with applicable regulations in your jurisdiction(s). ## Key Takeaway The EU AI Act and similar emerging regulations are reshaping how AI tools are developed and deployed globally. Libraries should be aware of these regulatory developments and proactively engage with legal counsel and vendors to understand compliance implications. You don't need to become an AI regulation expert. But you should: - Consult with legal counsel about your specific compliance obligations - Ask vendors clear questions about their regulatory compliance status - Document your governance approach to AI tool decisions - Stay informed about evolving regulations Vendor approaches to compliance are still evolving. By asking informed questions and maintaining documented decision-making processes, you position your library to adapt as requirements become clearer. This article provides educational background on emerging AI regulation. For specific legal advice about your library's compliance obligations, consult qualified legal counsel. --- **Want to dig deeper?** The actual EU AI Act is available online (search "EU AI Act full text"), though I recommend coffee and patience. For a more digestible version, the European Commission has a summary document that\'s actually readable. Colorado\'s AI Act (SB 24-205) is also worth reviewing if you're U.S.-based. **Questions about your specific situation?** That's literally what I do. [Get in touch](#contact).