Article 105: Amendment to Directive 2014/90/EU

Article 105 brings Directive 2014/90/EU — the Marine Equipment Directive (MED) — into the AI Act's integrated compliance framework. The MED governs equipment placed on board EU-flagged ships that must meet international maritime safety standards (SOLAS, MARPOL, COLREG). Equipment bearing the MED wheel mark has been assessed for conformity with these standards.

As the maritime sector increasingly adopts AI — in navigation systems, autonomous vessel operations, collision avoidance, engine monitoring, environmental compliance systems, and crew assistance tools — the amendment ensures that AI-specific requirements are addressed during the MED conformity assessment process. This follows the Article 8 integration model: AI Act obligations are not a separate certification track but are woven into the existing MED assessment.

The maritime context adds unique challenges for AI compliance: vessels operate in remote environments with limited connectivity, in extreme weather, and under international maritime conventions (IMO standards) that exist alongside EU law. Risk management and human oversight must account for these operational realities.

• Article 8 — Integration with sector legislation: AI Act requirements for high-risk systems are assessed through existing product conformity assessment when the product is covered by Annex I legislation. Article 105 activates this for marine equipment.
• Annex I — Union harmonisation legislation: after the amendment, marine equipment with AI components falls under the integrated AI Act assessment regime.
• Article 9 — Risk management: maritime AI systems must address sector-specific hazards: equipment failure at sea, degraded-mode operation, limited human access for intervention, and interaction with international maritime safety conventions.
• Article 14 — Human oversight: bridge officers and engineers must retain meaningful decision authority over AI-powered navigation and safety systems — consistent with COLREG and SOLAS requirements for watchkeeping.
• Article 113 — Entry into force and application dates: confirms when Article 105 becomes enforceable.

For marine equipment manufacturers: - Identify all AI components in your product range: navigation radar with ML-based target classification, ECDIS route optimisation, autonomous docking systems, fire detection AI, engine monitoring, and emission compliance systems. - Prepare AI Act documentation (risk management, data governance, technical documentation, human oversight design) and integrate it into your MED type-examination technical file. - Engage your notified body early — many MED notified bodies may need to develop AI assessment competencies. Discuss the scope of AI-related assessment before submitting.

For ship operators (deployers): - Review procurement contracts for new AI-equipped marine equipment to require evidence of AI Act compliance alongside MED certification. - Ensure bridge officers and engineers are trained on AI system capabilities, limitations, and override procedures — this supports both the AI Act's human oversight requirements and STCW (Standards of Training, Certification and Watchkeeping) obligations. - Implement post-deployment monitoring: log AI system decisions and flag anomalies for review, particularly for navigation and collision avoidance systems.

For notified bodies: - Develop assessment competence for AI components embedded in marine equipment — this may require collaboration with AI domain experts or upskilling existing assessors. - Ensure assessment procedures cover AI-specific elements: training data quality, model robustness in maritime conditions, cybersecurity of AI systems on networked vessels, and human-machine interface design.