EU AI Act for Logistics & Transport: Route AI, Infrastructure & High-Risk Triggers
Logistics and transport companies rely on AI for route optimisation, demand forecasting, warehouse automation and fleet management. Under the EU AI Act (Regulation (EU) 2024/1689), most of these uses are minimal-risk with no mandatory obligations. The exceptions are specific: AI acting as a safety component in road-traffic management, and AI managing the warehouse or driver workforce, which fall into the high-risk tier.
Is it in scope?
Core logistics AI — routing, ETA prediction, load planning, inventory optimisation — is not listed in Annex III and is generally minimal-risk. Two triggers can escalate a system. Annex III(2) lists AI used as a safety component in the management and operation of road traffic, which can reach certain traffic-management deployments. Annex III(4) covers worker management, so AI that allocates tasks, routes drivers or monitors warehouse staff productivity is high-risk on the employment ground. Autonomous delivery vehicles engage the product-safety route (Art. 6, from 2 August 2027).
Typical AI use cases
- Route optimisation and ETA prediction
- Demand and capacity forecasting
- Warehouse robotics and pick-path optimisation
- Driver and warehouse-worker task allocation
- Fleet telematics and predictive maintenance
Risk classification
For most operators, logistics AI is minimal-risk — routing, forecasting and warehouse optimisation carry no mandatory obligations beyond AI literacy under Art. 4. Escalation is targeted: AI used as a safety component in road-traffic management is high-risk under Annex III(2), and AI that manages or monitors workers (task allocation, productivity tracking of drivers and warehouse staff) is high-risk under Annex III(4), from 2 August 2026, with Art. 26 deployer duties including worker information. Autonomous vehicles follow the product-safety route with its 2 August 2027 deadline.
Obligations to prepare for
Your exact duties also depend on whether you build or use the AI. See obligations by operator role — provider, deployer, importer, distributor or GPAI provider.
FAQ
Is route-optimisation AI regulated?
Generally it is minimal-risk. Routing, ETA prediction and load planning are not listed in Annex III and carry no mandatory AI Act obligations, though staff should have adequate AI literacy under Art. 4.
We use AI to assign and monitor drivers — is that high-risk?
Yes. AI that allocates tasks to workers or monitors their performance falls under the Annex III(4) employment listing and is high-risk from 2 August 2026. As deployer you carry Art. 26 duties, including informing the affected drivers and ensuring human oversight.
What about autonomous delivery vehicles?
AI that performs a safety function in an autonomous vehicle is high-risk through the product-safety route under Art. 6(1), with obligations applying from 2 August 2027 rather than the 2 August 2026 date for most Annex III uses.
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