# Conformity Assessment Route (T0.5)

Per EU AI Act Article 6 + Annex III, cubie-eu's intended use case (silicon-rooted
admission gate for high-risk AI inference, with PUF-bound identity) is most
likely classified under **Annex III point 1 (biometric identification systems)**
when the PUF is used as a hardware identifier of the inferring physical device.

## Determination

- **Annex III applicability:** YES — PUF silicon-binding qualifies as biometric
  identification of the platform (Recital 54). Notified body review is required.
- **Article 5 prohibited-use exclusions:** Reviewed; cubie-eu is not a
  prohibited practice (no social scoring, no real-time public biometric
  identification, no manipulation of vulnerable persons).
- **Conformity route:** **Annex VII (third-party notified body assessment)** is
  required because the system is in Annex III point 1.

## Notified Body Engagement

Lead time: 6-12 weeks. Initiate immediately in parallel with v0.1 development.

Candidate notified bodies (EU AI Act-designated, by Member State):
- TÜV SÜD (DE)
- BSI Group (UK / DE branch)
- DEKRA (DE)
- Bureau Veritas (FR)
- (List to be refined per latest Commission designations.)

## Component vs Standalone

cubie-eu may also be deployed as a **component** of a customer's larger AI system.
In that case the system integrator carries the conformity obligation, not
Centillion. The component-mode disclosure must accompany every distribution.

## Status

- [ ] Notified body identified
- [ ] Annex IV technical documentation drafted
- [ ] EU representative designated (per Art.25 if Centillion is non-EU)
- [ ] Conformity declaration signed (Art.47)
- [ ] CE marking applied (Art.49)