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    How will the EU AI Act affect reporting of AI environmental impact for deployers?

    For companies that use AI systems built by others and are asked what the EU AI Act means for their environmental reporting. Status checked on 12 November 2026 against the consolidated text on the Commission's AI Act Service Desk. General information and not legal advice.

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    How will the EU AI Act affect reporting of AI environmental impact for deployers?

    Not directly. The AI Act puts no energy or emissions reporting duty on deployers. The only energy documentation duty sits in Article 53 and Annex XI, and it binds providers of general-purpose AI models, who must document the known or estimated energy consumption of each model for the AI Office and national authorities on request. That duty has applied since 2 August 2025, and models placed on the market before then have until 2 August 2027. A company that calls an API or buys seats is a deployer or an integrator and has no Annex XI duty, unless it modifies a model with more than one-third of the original training compute and so becomes a provider for that modification. What changes for deployers is indirect. Provider documentation may improve over time, and a deployer's own AI emissions still have to be reported under the sustainability rules that apply to the company, not under the AI Act.

    Which parts of the AI Act touch energy or emissions, and who do they bind?

    Read from the consolidated Regulation on the Commission's AI Act Service Desk on 12 November 2026. Whether a deployer is affected is the last column.
    ProvisionWho it addressesWhat it asksDuty for a deployer
    Article 53(1)(a) with Annex XIProviders of general-purpose AI modelsTechnical documentation including known or estimated energy consumption of the model, provided to authorities on requestNone. The documentation is not published and is not routed to downstream users
    Article 53(5)The CommissionPower to adopt delegated acts on how to measure and calculate energy, for comparable and verifiable documentationNone. It is a power and not a duty, and we found no adopted act
    Article 112(6)The CommissionReport by 2 August 2028 on standards for energy-efficient development of general-purpose models, then every four yearsNone. It could lead to further measures later
    Article 50Providers and deployers of certain AI systemsTransparency about AI interaction and machine-readable marking of synthetic outputs. Nothing on energyTransparency duties only, and not environmental ones

    A statement that Article 50 or a deployer duty requires AI carbon reporting is an error. The full reading, with the dates and the Code of Practice, is in the EU AI Act energy documentation guide.

    Where does a deployer's AI footprint get reported instead?

    In its own sustainability reporting. A company within the CSRD scope reports Scope 3 emissions under ESRS E1, and purchased AI belongs in Category 1 on our reading. Under Directive (EU) 2026/470, the Omnibus I amendment, the CSRD covers undertakings with more than 1,000 employees and more than EUR 450 million net turnover, for financial years starting on or after 1 January 2027. Companies outside the scope can still account for AI voluntarily, for customers, lenders or procurement questionnaires. The Scope 3 and CSRD guide shows the method, and the AI Act does not change it.

    What can a deployer do now?

    • Ask providers directly for energy, region and facility data. The AI Act gives no right to the Annex XI figure, but nothing stops the request.
    • Estimate the footprint from your own usage exports with an open, versioned factor set, and mark it as an estimate with its range.
    • Keep the provider's answers on file, since they are what lets you move from an estimate to supplier-specific data if one ever becomes available.

    SOMA AI, which publishes this page, offers open factors for the estimate, and the AI Act does not approve or require any particular factor set.

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