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AI law comparison · Data verified 2026-08-22

EU AI Act — Medical Device AI vs Maryland Healthcare AI Act

EU AI Act — Medical Device AI and Maryland Healthcare AI Act are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.

Find which laws apply to my business

Side by side

Attribute
EU AI Act — Medical Device AI
Maryland Healthcare AI Act
Region
EU
US-MD
Effective date
2024-08-01
2024-04-22
Enforcement begins
2028-08-02
Who must comply
Applies to: providers (and, in their respective roles, deployers, importers, and distributors) of AI systems that are, or are a safety component of, a medical device or in-vitro diagnostic device subject to third-party c…
THREE SURFACES, DIFFERENT SCOPES AND DIFFERENT LEGAL WEIGHT — the distinction is the point and must not be smoothed over. (A) MIA BULLETIN 24-11 (22 Apr 2024) reaches ALL Insurers, Nonprofit Health Service Plans, Health…
Maximum penalty
€15,000,000 or 3% of global annual turnover for high-risk AI violations
No AI-specific penalty schedule exists; exposure routes to the existing Insurance Article tracks (all fetched from mgaleg.maryland.gov this round): Md. Code, Insurance § 4-113(d) — instead of or in addition to suspending or revoking a certificate of authority, a penalty of not less than $100 but not more than $125,000 for EACH violation of the article, plus restitution to any person who suffered financial injury; § 27-305(a) — not exceeding $2,500 for each violation of § 27-303 (unfair claim settlement practices) and not exceeding $125,000 for each violation of § 27-303(9); § 15-10B-12(b)(4) — an administrative penalty of up to $5,000 for each violation of any provision of the private-review-agent subtitle (which is where § 15-10B-05.1 sits), alongside certificate denial/suspension/revocation, cease-and-desist, and patient restitution; § 15-10B-12(a) — misdemeanor, penalty not exceeding $1,000, each day a violation continues after the first conviction a separate offense; and § 1-301 — a willful violation of the article is a misdemeanor subject to a fine not exceeding $100,000.
Compliance requirements
3 tracked
19 tracked
Enforcement actions on record
None on record yet
None on record yet
Data last verified
2026-08-22
2026-08-26

Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.

The key difference

Maryland Healthcare AI Act takes effect first, so it is usually the more urgent of the two. EU AI Act — Medical Device AI tracks 3 compliance requirements and Maryland Healthcare AI Act tracks 19. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.

EU

EU AI Act — High-Risk Medical Device AI (Article 6 / MDR / IVDR)

EU AI Act Article 6(1) classifies AI systems embedded in EU-regulated medical devices as high-risk. Any AI-powered medical device subject to third-party conformity assessment under MDR (Class IIa, IIb, III) or IVDR (Class B, C, D) must comply with the full EU AI Act high-risk regime by August 2, 2028 (DEFERRED from the original 2 Aug 2027 by the Digital Omnibus — Regulation (EU) 2026/1744, published in the Official J…

Full EU AI Act — Medical Device AI requirements
US-MD

Maryland Insurance AI Surface — MIA Bulletin 24-11, HB 820/SB 474 Utilization-Review AI (Ins. § 15-10B-05.1), and Bulletin 25-10 Imagery

Maryland regulates insurance AI on THREE stacked surfaces, and only the third is healthcare-specific. (1) MIA BULLETIN 24-11, "The Use of Artificial Intelligence Systems in Insurance", issued 22 April 2024 by Commissioner Kathleen A. Birrane to all Insurers, Nonprofit Health Service Plans, Health Maintenance Organizations, and Dental Plan Organizations ("Carriers") holding a Maryland certificate of authority — Maryla…

Full Maryland Healthcare AI Act requirements

Common questions

Could both EU AI Act — Medical Device AI and Maryland Healthcare AI Act apply to my business?

Yes. EU AI Act — Medical Device AI and Maryland Healthcare AI Act are separate regulations with separate scopes — a business can fall under both at once. EU AI Act — Medical Device AI covers Applies to: providers (and, in their respective roles, deployers, importers, and distributors) of AI systems that are, or are a safety component of, a medical d… Maryland Healthcare AI Act covers THREE SURFACES, DIFFERENT SCOPES AND DIFFERENT LEGAL WEIGHT — the distinction is the point and must not be smoothed over. If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.

Which has the higher maximum penalty — EU AI Act — Medical Device AI or Maryland Healthcare AI Act?

EU AI Act — Medical Device AI: €15,000,000 or 3% of global annual turnover for high-risk AI violations Maryland Healthcare AI Act: No AI-specific penalty schedule exists; exposure routes to the existing Insurance Article tracks (all fetched from mgaleg.maryland.gov this round): Md. Code, Insurance § 4-113(d) — instead of or in addition to suspending or revoking a certificate of authority, a penalty of not less than $100 but not more than $125,000 for EACH violation of the article, plus restitution to any person who suffered financial injury; § 27-305(a) — not exceeding $2,500 for each violation of § 27-303 (unfair claim settlement practices) and not exceeding $125,000 for each violation of § 27-303(9); § 15-10B-12(b)(4) — an administrative penalty of up to $5,000 for each violation of any provision of the private-review-agent subtitle (which is where § 15-10B-05.1 sits), alongside certificate denial/suspension/revocation, cease-and-desist, and patient restitution; § 15-10B-12(a) — misdemeanor, penalty not exceeding $1,000, each day a violation continues after the first conviction a separate offense; and § 1-301 — a willful violation of the article is a misdemeanor subject to a fine not exceeding $100,000. Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.

When does each law take effect?

EU AI Act — Medical Device AI — effective 2024-08-01, enforcement from 2028-08-02. Maryland Healthcare AI Act — effective 2024-04-22. Dates last verified against official sources on 2026-08-22 and 2026-08-26 respectively.

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