The next AI Act date is 2 December. For most of you it is a supplier question.

This analysis first appeared as the weekly Praxikon newsletter.

<h2>The next hard date falls in 99 days</h2> <p>Article 50 has applied since 2 August and the enforcement powers are active. The next hard date in the regulation is 2 December 2026, 99 days from now. Two things converge on that date.</p> <ul> <li><strong>The end of the only transitional period inside Article 50.</strong> The machine-readable marking and detectability required by paragraph 2 must by then also be in place for generative systems already on the market before 2 August 2026. Systems placed on the market after that date never had a transitional period at all.</li> <li><strong>The new prohibitions in Regulation (EU) 2026/1744.</strong> AI intended to generate child sexual abuse material or non-consensual intimate imagery is prohibited from that date. Providers of generative image, video and audio models must by then have put reasonable and adequate technical safeguards in place, such as training-data filtering and input and output classifiers.</li> </ul> <h2>What does this mean for your organisation?</h2> <p>It pays to be precise about who owes what. Article 50(2) rests on the provider, not on you as a deployer. If you use generative AI that you have procured, 2 December is not a build task but a supplier question. The question is whether your supplier marks output by that date, in what form, and whether you have that answer in writing.</p> <p>The opposite mistake is at least as expensive. What does rest directly on you, paragraphs 3 and 4, never had a transitional period: informing people exposed to emotion recognition and biometric categorisation, labelling deepfakes, and labelling AI-generated text published to inform the public. That has applied since 2 August. Treating December as the start date for your own labelling policy puts you four months late.</p> <h2>More nuanced than it looks: the first standard exists, the legal effect does not</h2> <p>On 12 July, CEN and CENELEC published the first European standard developed specifically for the AI Act: EN 18286:2026 on the quality management system, the standard supporting Article 17 for providers of high-risk systems. Publication is not the same as a presumption of conformity. That arises only once the Commission has the standard cited in the Official Journal, which has not yet happened. You can therefore use the standard to structure your set-up towards 2 December 2027, but not yet to claim that you meet Article 17.</p> <h2>Action for this week</h2> <p>Put one written question to each generative AI supplier and record the answer: do you mark output in a machine-readable way under Article 50(2), from which date, and in which format. Alongside that, list which of your generative applications were already in use before 2 August 2026, because only those fall under the transitional period. Keep the answer, the date and the sender. That is the only evidence you will hold in December.</p> <p>If it comes down to what the contract actually says, have a look at the <a href="https://embedai.nl/en/diensten/ai-vendor-contract-check?utm_source=praxikon&utm_medium=referral&utm_campaign=praxikon_weekly&utm_content=editie-2026-08-25">AI vendor and contract check by Embed AI</a>, which sets out which AI Act role sits with whom, which supplier evidence is missing and which questions to hand to procurement.</p> <p>You receive this weekly AI Act update because you signed up with Praxikon, formerly Praxikon, or used one of our tools or templates. You can unsubscribe with one click at the bottom.</p> <p>Until next Tuesday.<br/>Zahed Ashkara<br/>Praxikon</p>