AI Liability in the MENA Region: What the EU AI Act Means for Lebanese Businesses
The EU AI Act is now in force. For Lebanese companies exporting AI-powered products or services to European markets, the compliance window is closing. We examine the extraterritorial reach of the Act and what regional businesses must do now.
The EU Artificial Intelligence Act entered into force in August 2024, establishing the world's first comprehensive legal framework for artificial intelligence. While its primary jurisdiction is the European Union, its extraterritorial provisions have significant implications for businesses in Lebanon and the broader MENA region.
Under Article 2 of the Act, any provider placing an AI system on the EU market — regardless of where that provider is established — falls within scope. This means a Lebanese software company whose AI-powered product is used by a single EU-based customer is, in principle, subject to the Act's requirements.
The risk-based classification system divides AI systems into four tiers: unacceptable risk (prohibited), high risk (heavily regulated), limited risk (transparency obligations), and minimal risk (largely unregulated). High-risk systems — which include AI used in recruitment, credit scoring, biometric identification, and critical infrastructure — face the most stringent requirements: conformity assessments, technical documentation, human oversight mechanisms, and registration in the EU database.
For Lebanese businesses, the practical implications are threefold. First, any company with EU market ambitions must audit its AI systems against the Act's risk classification framework. Second, contracts with EU customers should be reviewed to ensure appropriate liability allocation. Third, internal governance structures — AI ethics boards, documentation protocols, incident response procedures — must be established before market entry.
The compliance timeline is not forgiving. Prohibited AI practices became enforceable in February 2025. High-risk system requirements apply from August 2026. General-purpose AI model obligations are already in effect. Companies that have not begun their compliance journey are already behind.
This article is published for informational purposes only and does not constitute legal advice. For advice specific to your situation, please contact Orbilex directly.
Related Insights
Need Counsel on This Topic?
Our team advises on the exact issues covered in this article. Contact us to discuss your specific situation.