Praxikon

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.

14 moments behind us, 6 still ahead

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, overgangsregime bij artikel 50 lid 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 | Verordening (EU) 2026/1744, wijziging van artikel 5

  • 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 providersArticle 55: GPAI models with systemic risk

    Source: EU Artificial Intelligence Act 2024/1689 | Article 111(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 AIArticles 43-49: conformity assessment, CE and registration

    Source: Digital Omnibus on AI 2026/1744 | Verordening (EU) 2026/1744, gewijzigde toepassingsdata bij artikel 113

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 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 onder normalisatieverzoek 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 | Praktijkcode transparantie AI-gegenereerde inhoud, 10 juni 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 AIArticles 43-49: conformity assessment, CE and registration

    Source: Draft guidelines on the classification of high-risk AI systems | Ontwerprichtsnoeren van 19 mei 2026, bijlagen over Bijlage I en Bijlage 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 providersArticle 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 AIArticle 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 providersArticle 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 | Praktijkcode voor AI voor algemene doeleinden, 10 juli 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 literacyArticle 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 literacyArticle 5: prohibited practices

    Source: EU Artificial Intelligence Act 2024/1689 | Article 113