The EU AI Act: the law
Regulation (EU) 2024/1689 regulates uses of AI rather than a technology: the more a use can harm people, the heavier the obligations. It makes no humanitarian exception. An NGO is almost always a deployer: it uses tools designed by others, and its obligations cannot be handed over to the provider.
Some practices have been banned since February 2025, including exploiting vulnerabilities and social scoring. The transparency obligation has applied since 2 August 2026. High-risk rules, which directly cover access to essential aid, emergencies and migration, were postponed to 2 December 2027 by the July 2026 AI omnibus. The same omnibus reworded Article 4: organisations must now support the development of AI literacy among their staff, and be able to show what they have done.
A national organisation with no link to the EU is not directly subject to it. Its European donors and partners are, and they pass these requirements on through their contracts, as they did with the GDPR. The details, article by article: the EU AI Act explained for humanitarian organisations.
SAFE AI: the sector standard
SAFE AI (Standards and Assurance Framework for Ethical Artificial Intelligence) is the AI governance framework designed for humanitarian action, published as version 1.1 in May 2026 by the CDAC Network, the Alan Turing Institute and Humanitarian AI Advisory. It is voluntary, and goes further than the law on humanitarian principles and the role of communities.
It classifies each use case, not each tool, into three risk levels, and takes every project through four stages, each closed by a decision: continue, redesign, pause or stop. It recognises responsible refusal as a valid outcome: not using AI is a SAFE AI result in its own right. Its central document is the transparency card, published before going live. The full framework: SAFE AI, the humanitarian AI framework.
In practice: two tools put to the test
Principles alone are not enough to judge a tool. During the session, I apply both texts to two real uses, on Opti', the MEAL platform I designed. I say so at the start: it serves as evidence, and each demonstration also shows its limits.
Each method page comes with a pre-filled SAFE AI transparency card, editable in Word, so you can see what the document looks like once completed.