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Direct answer

When do the AI Act obligations start to apply to the AI value chain?

4 obligations under the AI Act bear on this, of which 1 applies today.

First step: Run the four verifications of Article 23(1) before importing.

The obligations for the AI value chain do not all start on the same day. They spread over 2 groups, from 2 August 2025 to 2 December 2027. Below is when each provision starts to apply.

The conclusion and your first steps

This applies now

Coming up

When it starts to apply

Read the official sourceChecked on

General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.

Full map for your situation

Your route

From your situation, via your role, to what applies and when it starts.

1 now · 3 later

Your situation

The obligations for the AI value chain do not all start on the same day. They spread over 2 groups, from 2 August 2025 to 2 December 2027. Below is when each provision starts to apply.

Applies now

From 2 December 2027

To record: Importer dossier with ten-year retention · Distributor log of checks and corrective actions · Mandate file of the authorised representative

Source and locator

Every statement above rests on these texts. The locator points to the place in the text, the version and the date say which edition was checked.

  • EU Artificial Intelligence Act 2024/1689

    European Parliament and Council, version original-oj-2024-07-12, checked on , ELI http://data.europa.eu/eli/reg/2024/1689/oj

    Locators in this source

    • Article 23(1)-(7)
    • Article 24(1)-(6)
    • Article 54(1)-(6)
    • Article 3(5)
    • Article 113(3)(b)
    • Article 101(1)-(6)
    • Article 111(3)
    • Articles 22 and 25

  • Digital Omnibus on AI 2026/1744

    European Parliament and Council, version official-journal-2026-07-24, checked on , ELI http://data.europa.eu/eli/reg/2026/1744/oj

    Locators in this source

    • Article 1, point (40)(b) and (c), replacing Article 113, third paragraph, point (c) and adding point (d)
    • Amended Article 113 application dates

Dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0, schema 1.5.0.

Execution

Make supplier information and commitments verifiable

Your own file partly depends on information, instructions and commitments from the provider or supplier. Embed AI checks which materials are missing and translates those gaps into contractual and operational actions. The source interpretation above is separate from this commercial referral by Praxikon to an affiliated brand.

See the vendor and contract approach
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Zahed Ashkara, jurist and freelance AI & Privacy Consultant

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Zahed Ashkara

Freelance AI & Privacy Consultant, jurist

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