Changes

What changed, and since when

The AI Act did not start applying all at once. This timeline shows, moment by moment, which duty took effect, what the Digital Omnibus moved and which official guidance appeared. Every line points at its source.

17 moments behind us, 9 still ahead

Timeline

17 behind us · 9 still ahead

Next up: Grace period for machine-readable marking ends, 2 December 2026.

Still ahead

2026-12-02 | upcoming
Grace period for machine-readable marking ends
Systems placed on the market before 2 August 2026 must comply with Article 50(2) by 2 December 2026.
Article 50 has applied to all systems in scope since 2 August 2026. For the machine-readable marking and detectability of paragraph 2 a transition period runs to 2 December 2026, and only for systems placed on the market before 2 August 2026.
Touches:Article 50: transparency
Source: Guidelines on Article 50 | Commission Guidelines C(2026) 5054 final, transitional regime under Article 50(2)
2026-12-02 | upcoming
New prohibitions require technical safeguards
The Digital Omnibus prohibits AI for child sexual abuse material and non-consensual intimate imagery.
Regulation (EU) 2026/1744 adds a prohibition on AI intended to generate child sexual abuse material or non-consensual intimate imagery. The required technical safeguards must be in place by 2 December 2026.
Touches:Article 5: prohibited practices
Source: Digital Omnibus on AI 2026/1744 | Regulation (EU) 2026/1744, amendment of Article 5
2027-08-02 | binding law
New Article 2(13): requirements for Annex I systems may be limited
Since 27 July 2026 the application of the requirements or obligations in Articles 9 to 15 and 17 to 25 may be limited for high-risk systems referred to in Article 6(1) where the Annex I Section A harmonisation legislation provides an equivalent or higher level of protection. That limitation exists only once a delegated act is adopted, which must happen by 2 August 2027. Until then the requirements apply in full.
Article 1, point (3), of Regulation (EU) 2026/1744 adds a paragraph 13 to Article 2. Its final subparagraph provides: by 2 August 2027, the Commission shall adopt delegated acts in accordance with Article 97 in order to supplement this Regulation by specifying the high-risk AI systems concerned, the requirements or obligations that may be limited, the conditions under which such limitation applies, and the scope of the limitation.
Touches:Articles 43-49: conformity assessment, CE and registration
Source: Digital Omnibus on AI 2026/1744 | Article 1, point (3), inserting Article 2(13)
2027-08-02 | upcoming
Legacy GPAI models must comply
Models placed on the market before 2 August 2025 have until 2 August 2027.
Article 111(3) gives providers of GPAI models placed on the market before 2 August 2025 until 2 August 2027 to comply with Chapter V.
Touches:Article 53: GPAI model providers Article 55: GPAI models with systemic risk
Source: EU Artificial Intelligence Act 2024/1689 | Article 111(3)
2027-08-02 | upcoming
National AI regulatory sandboxes operational on 2 August 2027
The first subparagraph of Article 57(1) has been replaced. The date by which each Member State must have at least one AI regulatory sandbox operational moved from 2 August 2026 to 2 August 2027. For a provider that is the day the route to supervised testing actually exists.
Article 1, point (22)(a), of Regulation (EU) 2026/1744 replaces the first subparagraph of Article 57(1) with: Member States shall ensure that their competent authorities establish at least one AI regulatory sandbox at national level, which shall be operational by 2 August 2027.
Touches:Article 57: AI regulatory sandboxes
Source: Digital Omnibus on AI 2026/1744 | Article 1, point (22)(a), replacing Article 57(1), first subparagraph
2027-09-02 | upcoming
Template for the post-market monitoring plan becomes guidance, by 2 September 2027
Article 72(3) has been replaced. The original text required an implementing act with a template by 2 February 2026, and that deadline had passed without an act. Since 27 July 2026 it is guidance including a template, to be adopted by 2 September 2027. There is therefore no overdue implementing act; anyone waiting for the old template is waiting for something that will not come.
Article 1, point (30), of Regulation (EU) 2026/1744 replaces Article 72(3) with: the post-market monitoring system shall be based on a post-market monitoring plan. The post-market monitoring plan shall be part of the technical documentation referred to in Annex IV. The Commission, taking utmost account of the opinion of the Board, shall adopt guidance, including a template, on the post-market monitoring plan by 2 September 2027.
Touches:Article 72: post-market monitoring
Source: Digital Omnibus on AI 2026/1744 | Article 1, point (30), replacing Article 72(3)
2027-12-02 | binding law
Annex III core rules moved to 2 December 2027
The amended application date has been binding law since 27 July 2026.
Regulation (EU) 2026/1744 sets application for Article 6(2) and Annex III on 2 December 2027.
Touches:Annex III: high-risk AI
Source: Digital Omnibus on AI 2026/1744 | Amended Article 113
2027-12-02 | binding law
FRIA follows new date and may cross-reference a DPIA
The FRIA for the relevant Annex III route follows 2 December 2027 and may include or cross-reference relevant DPIA elements.
The amending regulation links the relevant FRIA route to the new application calendar and expressly enables reuse through a DPIA.
Touches:Article 27: FRIA
Source: Digital Omnibus on AI 2026/1744 | Article 27 amendment and amended Article 113
2028-08-02 | upcoming
High-risk AI embedded in regulated products
AI as a safety component of products under Annex I follows on 2 August 2028.
For AI systems under Article 6(1) and Annex I, that is AI as a safety component of products already covered by EU product legislation, the high-risk requirements apply from 2 August 2028.
Touches:Annex III: high-risk AI Articles 43-49: conformity assessment, CE and registration
Source: Digital Omnibus on AI 2026/1744 | Regulation (EU) 2026/1744, amended application dates under Article 113

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Behind us

2026-08-02 | applicable
GPAI enforcement powers active
Since 2 August 2026 the Commission can request GPAI information, conduct evaluations and require measures.
Commission enforcement powers for GPAI and the Article 101 fine regime have been active since 2 August 2026.
Touches:Article 53: GPAI model providers
Source: EU Artificial Intelligence Act 2024/1689 | Articles 91-93, 101 and 113
2026-08-02 | applicable
Article 50 is applicable
The transparency duties apply since 2 August 2026.
Article 50 became applicable on 2 August 2026 and was not postponed by the Digital Omnibus.
Touches:Article 50: transparency
Source: EU Artificial Intelligence Act 2024/1689 | Article 50 and Article 113
2026-07-27 | binding law
Article 6 gains paragraphs 1a to 1c on safety components
Since 27 July 2026 AI systems solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components, unless failure or malfunctioning would endanger health and safety. A product required to undergo a third-party assessment only because of radio spectrum or electromagnetic interference that does not affect health and safety does not fulfil the condition in paragraph 1, point (b).
Article 1, point (8), of Regulation (EU) 2026/1744 inserts the following paragraphs into Article 6: 1a. For the purposes of this Regulation, including paragraph 1 of this Article, AI systems that are solely used for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control shall not qualify as safety components. 1b. Notwithstanding paragraph 1a, AI systems the failure or malfunctioning of which would endanger health and safety shall qualify as safety components.
Touches:Articles 43-49: conformity assessment, CE and registration
Source: Digital Omnibus on AI 2026/1744 | Inserted Article 6(1a)-(1c)
2026-07-27 | binding law
Machinery moves from Annex I, Section A, to Section B
Since 27 July 2026 point 1 of Section A of Annex I, the machinery directive, has been deleted and Regulation (EU) 2023/1230 has been added as point 21 to Section B. For AI in machinery the limited regime of the amended Article 2(2) therefore applies: only Article 6(1), Article 60a and Articles 102 to 112.
Article 1, point (41), of Regulation (EU) 2026/1744 provides: Annex I is amended as follows: (a) in Section A, point 1 is deleted; (b) in Section B, the following point is added: 21. Regulation (EU) 2023/1230 of the European Parliament and of the Council of 14 June 2023 on machinery and repealing Directive 2006/42/EC.
Touches:Articles 43-49: conformity assessment, CE and registration
Source: Digital Omnibus on AI 2026/1744 | Article 1, point (2)(a), replacing Article 2(2); Article 1, point (41), amending Annex I
2026-07-27 | binding law
Article 4a inserted, Article 10(5) deleted
Since 27 July 2026 the legal basis for bias detection using special categories of personal data sits as Article 4a in Chapter I and no longer as Article 10(5) in Chapter III. The circle has widened from providers of high-risk systems alone to providers and deployers of other AI systems and models and deployers of high-risk systems, on the same conditions.
Regulation (EU) 2026/1744 inserted Article 4a and deleted Article 10(5) with effect from 27 July 2026. Anyone justifying a processing operation by reference to Article 10(5) has since been referring to a deleted provision.
Touches:Article 4a: legal basis for bias testing with special categories of personal data
Source: Digital Omnibus on AI 2026/1744 | Article 1, point 6 (insertion) and point 9 (Article 10 amended, paragraph 5 deleted)
2026-07-27 | binding law
Article 4 amended to a duty to take measures
Since 27 July 2026 the organisational duty supports the development of AI literacy without guaranteeing an individual level.
Regulation (EU) 2026/1744 amended Article 4 with effect from 27 July 2026.
Touches:Article 4: AI literacy
Source: Digital Omnibus on AI 2026/1744 | Article 4 amendment and entry into force
2026-07-20 | guidance
Final guidelines on Article 50
The Commission works out the transparency duties and confirms they apply from 2 August 2026.
Guidelines C(2026) 5054 final of 20 July 2026 work out the notification and marking duties of Article 50, with worked examples for chatbots, deep fakes and AI texts of public interest.
Touches:Article 50: transparency
Source: Guidelines on Article 50 | Commission Guidelines C(2026) 5054 final, 20.7.2026
2026-07-12 | guidance
First European AI Act standard approved
EN 18286:2026 on the quality management system is the first completed standard under the standardisation request.
CEN-CENELEC approved EN 18286:2026 on 12 July 2026. It is the first JTC 21 deliverable under standardisation request M/613 to reach the publication stage.
Touches:Article 17: quality management system
Source: CEN-CENELEC JTC 21: European standards under standardisation request M/613 | EN 18286:2026, CEN/CLC/JTC 21 under standardisation request M/613
2026-06-10 | guidance
Transparency Code of Practice published
A voluntary route to comply with parts of Article 50, in two separately signable sections.
The Code of Practice on transparency of AI-generated content appeared on 10 June 2026. After a positive adequacy assessment, signatories can rely on it for Article 50(2), (3) and (5). Section 1 addresses providers, section 2 deployers.
Touches:Article 50: transparency
Source: Code of Practice on transparency of AI-generated content | Code of Practice on Transparency of AI-generated Content, 10 June 2026
2026-05-19 | guidance
Draft guidelines on high-risk classification
The Commission explains in consultation when a system falls under Annex I or Annex III.
On 19 May 2026 the Commission published draft guidelines on the classification of high-risk AI systems for stakeholder consultation, with separate annexes on Annex I and Annex III. The text is non-binding and not yet final.
Touches:Annex III: high-risk AI Articles 43-49: conformity assessment, CE and registration
Source: Draft guidelines on the classification of high-risk AI systems | Draft guidelines of 19 May 2026, annexes on Annex I and Annex III
2025-08-02 | applicable
GPAI model obligations apply
Since 2 August 2025 the obligations for providers of general-purpose AI models apply.
Chapter V became applicable on 2 August 2025. Models placed on the market before that date must comply by 2 August 2027 at the latest.
Touches:Article 53: GPAI model providers Article 55: GPAI models with systemic risk
Source: EU Artificial Intelligence Act 2024/1689 | Articles 53 to 55 and Article 111(3)
2025-07-29 | guidance
Guidelines on prohibited AI practices
Worked examples for each Article 5 prohibition, with the line between permitted and prohibited.
Guidelines C(2025) 5052 final of 29 July 2025 work out each Article 5 prohibition with examples. The guidelines are non-binding: authoritative interpretation rests with the Court of Justice.
Touches:Article 5: prohibited practices
Source: Guidelines on prohibited AI practices, C(2025) 5052 final | Commission Guidelines C(2025) 5052 final, 29.7.2025
2025-07-29 | guidance
Guidelines on the definition of an AI system
The Commission draws the line between software that does and does not fall under the regulation.
Guidelines C(2025) 5053 final of 29 July 2025 explain Article 3(1) through borderline cases, such as classical optimisation, statistical estimation and expert systems.
Touches:Annex III: high-risk AI Article 4: AI literacy
Source: Guidelines on the definition of an AI system, C(2025) 5053 final | Commission Guidelines C(2025) 5053 final, 29.7.2025
2025-07-18 | guidance
Guidelines on the scope of the GPAI obligations
The Commission explains when someone becomes the provider of a GPAI model, including through fine-tuning.
Guidelines C(2025) 5045 final of 18 July 2025 describe the scope of the obligations for providers of GPAI models, including when a party modifying a model becomes a provider itself.
Touches:Article 53: GPAI model providers Article 55: GPAI models with systemic risk
Source: Guidelines for GPAI model providers | Commission Guidelines C(2025) 5045 final, 18.7.2025
2025-07-10 | guidance
General-Purpose AI Code of Practice published
The voluntary code of practice gives GPAI model providers a route to demonstrate compliance.
The Commission published the General-Purpose AI Code of Practice on 10 July 2025. Signing is voluntary; signatories can rely on it to demonstrate compliance with the GPAI obligations.
Touches:Article 53: GPAI model providers
Source: General-Purpose AI Code of Practice | Code of Practice for General-Purpose AI, 10 July 2025
2025-02-02 | applicable
Prohibited practices and AI literacy apply
Since 2 February 2025 the Article 5 prohibition and the Article 4 AI literacy duty apply.
Chapter I and Chapter II became applicable on 2 February 2025. That makes the prohibited practices the first category with enforceable duties.
Touches:Article 4: AI literacy Article 5: prohibited practices
Source: EU Artificial Intelligence Act 2024/1689 | Article 113, second paragraph, point (a)
2024-08-01 | applicable
The AI Act enters into force
The regulation entered into force on 1 August 2024, after which the obligations followed in phases.
Regulation (EU) 2024/1689 appeared in the Official Journal on 12 July 2024 and entered into force on 1 August 2024. Article 113 sets out that most provisions only become applicable later.
Touches:Article 4: AI literacy Article 5: prohibited practices
Source: EU Artificial Intelligence Act 2024/1689 | Article 113