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EU AI Act

EU AI Act timeline: what applies in 2026, 2027 and 2028

The EU AI Act already has applicable obligations. In this context, an application date is the date when a requirement starts applying to the organizations or systems it covers. Article 50 generally applies from 2 August 2026. After the July 2026 amendment, the principal Chapter III Sections 1 through 3 high-risk dates are 2 December 2027 for the Annex III route and 2 August 2028 for the Annex I route. Those dates do not postpone every provision concerning high-risk systems. Transitions for older systems and models require separate analysis.

As of 2026-09-15. Current duties and route-specific application dates through 2028. General information, not legal advice.

In this sectionImplementation timeline

The dates that matter

DateWhat changesWho should careQualification
1 August 2024Original Act enters into force.Organizations tracking the legal instrument.Entry into force differs from application of individual duties.
2 February 2025Chapters I and II begin applying, including original prohibitions and literacy.Relevant providers, deployers and operators.Article 4 wording was amended in July 2026.
2 August 2025Chapter V GPAI obligations and specified governance/penalty provisions begin applying.GPAI providers and relevant authorities/supply-chain actors.Article 101 was excluded from this early date; older models have a transition.
27 July 2026Regulation (EU) 2026/1744 enters into force.Teams maintaining dates, classifications and current requirements.Adopted amendment; provisions with later application dates retain them.
2 August 2026General application, including Article 50, Article 101 and Chapter IX Commission enforcement.Covered system/model providers and deployers.Paragraph-specific Article 50 transition; Chapter IX high-risk coverage needs separate review.
2 December 2026New Article 5 sexual-content prohibitions apply.Actors supplying or using systems within the new conditions.Two distinct points, with intended-purpose and safeguard qualifications.
2 December 2026Specified older generative systems comply with Article 50(2).Providers of systems placed on the market before 2 August 2026.Marking/detection only; not a delay for all disclosures.
2 August 2027GPAI models placed before 2 August 2025 comply.Providers of qualifying older models.Model placement/modification history matters.
2 December 2027Chapter III Sections 1 through 3 apply for Article 6(2)/Annex III systems.Providers/deployers and other actors around those systems.Article 6(5) excluded; Article 111 and sector/dual-route analysis remain necessary.
2 August 2028Chapter III Sections 1 through 3 apply for Article 6(1)/Annex I systems, excluding Article 6(5).Relevant product-system providers and operators.Cumulative product conditions and Section B restrictions matter.

Two specialized longer transitions are outside most enterprise planning: the 2 August 2030 backstop for specified high-risk systems intended for public-authority use, and 31 December 2030 for qualifying Annex X large-scale IT components. Neither is a general extension for private-sector deployments.

What the July amendment changes

Regulation (EU) 2026/1744 was adopted on 8 July, published on 24 July and entered into force on 27 July 2026. In this baseline, the amended dates are law. Articles describing the old timetable or an unfinished Omnibus proposal should not be reused without checking the adopted provisions.

The timetable is only part of the change. The amended Article 4 preserves literacy measures without a specific individual attainment guarantee. Product/classification changes and new prohibited-content points also matter. Teams updating a date slide should review the changed substantive provisions, not simply move a deadline.

Why the Act has more than one date

The EU AI Act does not have one start date. It moves through several legal stages, and each stage answers a different question:

  • Adoption is when lawmakers approve the final text.
  • Entry into force is when the adopted law formally takes effect.
  • Application is when a particular requirement starts applying to the organizations or systems it covers.

These distinctions matter because the Act does not apply all at once. The requirements for high-risk systems follow one schedule, while Article 50(2) gives certain older generative AI systems a different transition period. Referring to a single EU AI Act deadline can therefore give an organization the wrong date for a particular system or obligation.

For planning, record each deadline with the facts behind it. That includes the version of the law, the specific requirement, why it applies, the organization's legal role, the system or model involved, and any relevant history or transition rule. Without that context, a reminder can go to the wrong owner or prompt the wrong work.

Existing systems and models

Article 111(2) addresses operators of high-risk systems placed on the market or put into service before the relevant date. Later significant changes in design determine whether the specified requirements apply, while Article 5 and the public-authority backstop remain preserved. This wording is not the same as "substantial modification" in other rules, so the review needs the system's actual history.

The Article 50 transition is narrower. It concerns paragraph 2 for qualifying older generative systems. Internally developed own-use coverage remains unresolved because the statutory placement wording differs from the inspected guidance's additional putting-into-service wording. The older GPAI transition is separate and concerns models placed before 2 August 2025.

What the timetable does not settle

The express postponement covers Chapter III Sections 1 through 3, except Article 6(5). Articles 72/73 are in Chapter IX and have the general statutory 2 August 2026 date. Their coverage interacts with postponed classification and grandfathering. The research flags that interaction rather than declaring all prospective high-risk monitoring and reporting universally active or universally delayed.

High-risk guidance remained draft in the inspected materials, with final adoption expected by end 2026. Article 50 formal guidance adoption remained unresolved. Standards publication and an OJ citation are also different events. No expected publication date should become a statutory compliance date in the table.

How to use the timeline

Begin with the role analysis, territorial scope and high-risk route. Review already-applicable Article 50 and literacy obligations separately. Then assign the relevant application date and transition to each obligation and owner. The readiness sequence translates those inputs into preparation work.

For planning, identify technical dependencies before the legal date. Logging or intervention features may need design work; documentation may require supplier information; notices need to be tested in released interfaces. A later application date is a scheduling input, not proof that implementation can wait until the final month. This is operational advice, not a statutory interim milestone.

FAQ

What applies now?

Within their scope, original prohibitions and literacy, GPAI Chapter V and Article 50 are already applicable at this source cutoff. Their exceptions and transitions differ.

Is the high-risk deadline still August 2026?

The principal Chapter III Sections 1 through 3 dates in the amended baseline are 2 December 2027 and 2 August 2028 by route. This does not settle every high-risk-related provision.

Can all Article 50 work wait until December 2026?

No. The transition for an older system concerns paragraph 2 marking and detection only. Other Article 50 duties have their own conditions and the general application date.

Next step

Use this timeline with the operational readiness page.

Primary sources

Use the consolidated text to navigate provisions and the authentic original and amending Official Journal acts for the legislation. Guidance and Q&A retain their separate legal status.

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