EU AI Act Compliance

Regulation (EU) 2024/1689
Last updated: 22 July 2026
Effective date: 22 July 2026

This page explains how ODREN LTD (formerly SKILLFORGE.VIP LTD until 11 May 2026), a private limited company incorporated in England and Wales, company number 15944303, with its registered office at 7 Manchester Square, London, England, W1U 3PQ ("SkillForge", "we", "us", "our"), addresses the requirements of Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (the "AI Act").

It is intended for Providers and for their Learners. It should be read together with the Terms and Conditions at /terms, the Privacy Policy at /privacy, and the Cookie Policy at /cookies.

At a glance

• SkillForge is not itself an operator of any high-risk AI system as of the effective date of this page. Where AI features are offered, we position ourselves as a deployer of general-purpose AI systems and as a provider of specific low-risk AI-assisted features.
• Providers who use SkillForge to admit Learners, evaluate their learning outcomes, or monitor exams with AI may become deployers of high-risk AI systems under Annex III, point 3. In that case, the Provider inherits the deployer obligations set out in Chapter III of the AI Act.
• Emotion recognition of Learners in an educational context is prohibited by Article 5(1)(f) of the AI Act since 2 February 2025 and is not permitted on SkillForge under any circumstance.
• From 2 August 2026, Article 50 transparency notices apply. Any AI-generated content, chatbot interaction, or synthetic media on the Platform is clearly labelled.
• The high-risk obligations for Annex III point 3 education systems apply from 2 December 2027, following the Digital Omnibus adopted in June 2026.

1. Our role under the AI Act

1.1 SkillForge operates the Platform. Where a functionality is powered by an AI system, our role under Article 3 of the AI Act is determined by the specific feature:

• We are typically a "deployer" of third-party general-purpose AI models integrated into the Platform to provide assistive features (for example content transcription, auto-caption, quiz generation, summarisation).
• We are a "provider" of purpose-built features that we develop in-house, in which case we assume the corresponding provider obligations for those features.
• We are neither the provider nor the deployer of AI systems that a Provider integrates independently into its Provider Content (for example an external AI tutor embedded via iframe).

1.2 Where a Provider uses SkillForge functionality (or third-party AI integrations enabled via SkillForge) to make or materially influence a decision on the admission of a Learner, the evaluation of learning outcomes, the assignment of a level of education, or the detection of prohibited behaviour during a test, that Provider acts as a deployer of a high-risk AI system under Annex III point 3, and is responsible for the deployer obligations. SkillForge assists Providers with tooling and documentation but does not, and cannot, discharge the Provider's obligations on the Provider's behalf.

2. Uses of AI on the Platform

2.1 Assistive features. We may offer, or in the future may offer, AI-assisted features that support content creation, discovery, and delivery. Examples include automatic captions and transcripts, translation of course descriptions, auto-tagging of lessons, quiz suggestion, and content summarisation. These features are configured so that a human user reviews and approves output before publication or issuance.

2.2 Agent-friendly access via x402. The Platform supports the x402 HTTP payment protocol to enable machine-to-machine or agentic AI payments for Course access. This functionality is a payment mechanism, not an AI system in the sense of the AI Act, but it interacts with autonomous agents.

2.3 What we do not do.

• We do not use emotion recognition of Learners.
• We do not use social scoring of natural persons.
• We do not use biometric categorisation of Learners for the purpose of inferring race, political opinions, trade-union membership, religious or philosophical beliefs, sex life, or sexual orientation.
• We do not use real-time remote biometric identification.
• We do not use AI to make solely automated decisions that produce legal or similarly significant effects on Learners without human review.

3. Risk classification of SkillForge features

3.1 The AI Act classifies AI systems into four tiers: unacceptable risk (prohibited), high risk, limited risk (transparency-only), and minimal risk. Our current inventory:

3.2 We keep this inventory current. When a new feature is added, we reassess the classification, update this table, and, where required, obtain Provider re-consent through a new banner or updated notice.

4. Prohibited practices, Article 5

The following practices are prohibited under Article 5 of the AI Act since 2 February 2025 and are not available on SkillForge, whether as a native feature or as an integration configurable by a Provider:

• Subliminal, manipulative, or deceptive techniques that materially distort a person's behaviour to their detriment
• Exploitation of vulnerabilities of natural persons due to age, disability, or specific social or economic situation, in a way likely to cause significant harm
• Social scoring of natural persons for general purposes
• Untargeted scraping of facial images from the internet or CCTV to build facial recognition databases
• Emotion recognition of natural persons in workplaces and educational institutions, except for medical or safety reasons
• Biometric categorisation of natural persons to infer race, political opinions, trade-union membership, religious or philosophical beliefs, sex life, or sexual orientation
• Real-time remote biometric identification in publicly accessible spaces for law enforcement, subject to narrow exceptions

If a Provider attempts to enable a prohibited practice via a third-party integration or a custom workflow, we will disable the feature and, if necessary, suspend the account under clause 15 of the Terms and Conditions.

5. Education systems classified as high-risk under Annex III point 3

5.1 Under Annex III point 3 of the AI Act, an AI system is high-risk when it is intended to be used:

• (a) to determine access or admission or to assign natural persons to educational and vocational training institutions at all levels
• (b) to evaluate learning outcomes, including when those outcomes are used to steer the learning process of natural persons in educational and vocational training institutions
• (c) to assess the appropriate level of education that an individual will receive or will be able to access, in the context of, or within, educational and vocational training institutions
• (d) to monitor and detect prohibited behaviour of students during tests, in the context of, or within, educational and vocational training institutions

5.2 The Act's scope covers educational and vocational training at all levels, including primary schools, universities, and corporate or professional training programmes.

5.3 Application date. Following the Digital Omnibus adopted in June 2026, the high-risk obligations under Chapter III of the AI Act for Annex III systems apply from 2 December 2027. This deferral does not affect the prohibitions in Article 5 or the transparency obligations in Article 50, which retain their earlier application dates.

5.4 Article 6(3) exemption. A system falling under Annex III point 3 is not high-risk if it does not pose a significant risk of harm to the health, safety, or fundamental rights of natural persons, including by not materially influencing the outcome of decision-making. This applies when the system performs a narrow procedural task, improves the result of a previously completed human activity, detects decision-making patterns without replacing human assessment, or performs a preparatory task. SkillForge features fall under this exemption when they are used strictly for support, review, and content generation with mandatory human sign-off, and never make or materially influence decisions on admission, evaluation, or exam integrity.

6. Article 50 transparency obligations

6.1 From 2 August 2026, the transparency duties under Article 50 apply on SkillForge as follows:

• Chatbots. Any conversational interface powered by an AI system will identify itself as an AI to the user before the user interacts with it, unless this is obvious from context.
• AI-generated content. Text, images, audio, or video generated or materially altered by an AI system and made available to Learners will be marked as such in a machine-readable format compliant with the Code of Practice on AI content marking published in June 2026, and, where technically feasible, with a visible label.
• Deepfakes. Any image, audio, or video content that appreciably resembles existing persons, objects, places, entities, or events, and would falsely appear to a person to be authentic, is disclosed as artificially generated or manipulated.
• Public-interest text. AI-generated text published to inform the public on matters of public interest is disclosed as such, unless subject to editorial responsibility.

6.2 SkillForge implements these obligations at Platform level by:

• Rendering a "AI-generated" badge on lessons or media flagged as such by the Provider or produced by SkillForge's own generative features
• Ensuring the chatbot support widget in the dashboard identifies itself as AI on first message
• Embedding a machine-readable provenance signal (C2PA-compatible) in AI-generated media served through the Platform, once the harmonised standard is finalised

7. Provider obligations

7.1 If, as a Provider, you use SkillForge or third-party AI integrations to:

• decide or materially influence which Learners are admitted to a Course
• grade exams or evaluate learning outcomes with legal or similarly significant effect on the Learner
• proctor exams or detect prohibited behaviour during tests
• assign a Learner to a level or track that determines what they can access next

then you may act as a deployer of a high-risk AI system under Annex III point 3 of the AI Act.

7.2 As a deployer of a high-risk AI system, you are responsible for, at least:

• Using the system in accordance with the instructions for use provided by the AI system provider
• Ensuring that natural persons assigned to oversee the system have the necessary competence, training, and authority (Article 26(2))
• Ensuring input data is relevant and sufficiently representative in view of the intended purpose (Article 26(4))
• Monitoring the operation of the system and reporting serious incidents to the AI system provider and the competent national authority (Article 26(5))
• Keeping the logs automatically generated by the high-risk AI system for an appropriate period, and at least six months (Article 26(6))
• Informing Learners that they are subject to the use of a high-risk AI system (Article 26(11))
• Cooperating with competent authorities on any action taken in relation to the high-risk AI system (Article 26(12))
• Performing a fundamental rights impact assessment before deployment when required by Article 27, in particular where you are a public authority or entity providing public services

7.3 SkillForge assists Providers by:

• Providing a Deployer Questionnaire in the dashboard that flags whether the Provider's intended use falls under Annex III point 3
• Making available the technical documentation of the AI systems we provide, as required under Article 13
• Keeping logs of AI outputs and human review actions accessible to the Provider for at least six months
• Publishing on this page a change log of AI features added to the Platform, together with their classification

7.4 SkillForge does not act as the Provider's compliance officer. Legal responsibility for classifying and operating a use case as a deployer of a high-risk AI system remains with the Provider.

8. Governance, staff, and AI literacy

8.1 Article 4 of the AI Act, in force since 2 February 2025, requires providers and deployers of AI systems to take measures to ensure a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf.

8.2 SkillForge maintains an internal AI Literacy Programme covering:

• The obligations of the AI Act by role (engineering, product, support, legal, sales)
• Prohibited practices under Article 5
• The Annex III point 3 education scope
• Provider deployer obligations, so support and sales staff can guide Providers correctly
• Transparency labelling under Article 50

Records of training completion are retained for the duration of employment and 3 years thereafter.

8.3 An internal AI Governance Committee reviews new AI features before rollout. Its remit includes AI Act classification, data protection impact assessment, security review, and content moderation.

9. Timeline of application to SkillForge

The timeline that governs SkillForge's compliance workstream:

• 1 August 2024Regulation (EU) 2024/1689 enters into force.
• 2 February 2025Prohibitions in Article 5 and AI literacy obligations under Article 4 apply. SkillForge does not offer any prohibited practice.
• 2 August 2025Obligations for general-purpose AI models under Chapter V apply. Where SkillForge integrates a general-purpose AI model, we rely on the model provider's compliance and reflect it in our documentation.
• 2 August 2026Article 50 transparency obligations apply. SkillForge activates the labelling and disclosure workflows described in Section 6.
• 2 December 2027High-risk obligations under Chapter III for Annex III systems apply, following the Digital Omnibus adopted in June 2026. Providers of, and deployers using, high-risk education AI systems must be compliant by that date.
• 2 August 2028High-risk obligations for AI systems that are safety components of products or that are themselves regulated products under existing EU sectoral legislation (Annex I) apply.

10. Changes to this page

We update this page when a new AI feature is added, when the classification of an existing feature changes, when the AI Act or its implementing acts are amended, and at least annually. Material changes are notified to Providers by email at least 30 days before they take effect.

11. Contact

Questions about AI Act compliance:

• AI governance: ai@skillforge.vip
• Privacy: privacy@skillforge.vip
• Legal: legal@skillforge.vip
• Postal: ODREN LTD, 7 Manchester Square, London, England, W1U 3PQ, United Kingdom