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Dec 2, 2026DeadlineEU
AI Act bans on non-consensual intimate material and CSAM apply; Article 50(2) grace ends
Article 5(1)(ba) and (bb), added by Regulation (EU) 2026/1744, apply from December 2, 2026. Point (ba) bans placing on the market, putting into service, or using an AI system that generates or manipulates realistic images, videos, audio, or similar material of the intimate parts of an identifiable natural person, or of an identifiable natural person engaged in sexually explicit activities, without the freely given, specific, informed, unambiguous, and explicit consent of that person for that generation or manipulation. Point (bb) bans placing on the market, putting into service, or using an AI system that generates or manipulates material or performance within the meaning of Article 2, points (c) and (e), of Directive 2011/93/EU (child sexual abuse material), except where a “without right” defence applies under national law. Under Article 5(1a), placing such a system on the market or putting it into service is prohibited only where that generation or manipulation is its intended purpose, or where its design, training, architecture, capabilities, or user-facing functionalities make it a reasonably foreseeable and reproducible outcome, without requiring significant technical modification, and the system does not have reasonable and adequate technical safety measures and other safeguards to reliably prevent it, taking into account reasonably foreseeable misuse, and to correct observed or reported misuse. Use is prohibited only where the deployer uses the system for the purpose of generating or manipulating such material or performance. Under Article 5(1b), for point (ba), an AI system that manipulates material in a way that does not increase the exposure of any depicted intimate parts or alter the nature of any depicted sexually explicit activities does not constitute manipulation. Article 111(4) sets the same date as the deadline by which providers of AI systems, including general-purpose AI systems, that generate synthetic audio, image, video, or text content and were placed on the market before August 2, 2026 must comply with the Article 50(2) marking duty.
Source: Regulation (EU) 2024/1689, consolidated text as of July 27, 2026, Articles 5(1)(ba), (bb), 5(1a), 5(1b), 111(4), and 113(a), EUR-Lex · Guide: EU AI Act penalties and prohibited practices
Applies to: All industries
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Dec 9, 2026DeadlineEU
Revised Product Liability Directive transposition deadline; software is a product
Member States must transpose Directive (EU) 2024/2853 by December 9, 2026, and it applies to products placed on the market or put into service after that date. Product includes software, and defectiveness takes into account a product's ability to continue to learn. A manufacturer cannot rely on the later-defect defense where the defect is due to software, updates, or a lack of updates necessary to maintain safety within its control. Free and open-source software supplied outside a commercial activity is excluded.
Source: Directive (EU) 2024/2853, EUR-Lex · Guide: AI compliance, layer by layer
Applies to: Manufacturers
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Jan 20, 2027DeadlineEU
EU Machinery Regulation applies, with third-party assessment for machine learning safety components
Regulation (EU) 2023/1230 replaces the Machinery Directive. Safety components with fully or partially self-evolving behaviour using machine learning approaches that ensure safety functions, and machinery with such embedded systems, are listed in Annex I Part A, so internal production control is not available. Annex III requires such control systems to stay within their defined task and movement space and to enable recording of safety-related decision data, kept for one year to demonstrate conformity on a reasoned request from a competent national authority.
Source: Regulation (EU) 2023/1230, consolidated text of July 27, 2026 (Article 54 as corrected, Article 25, Annex I Part A, Annex III), EUR-Lex · Guide: EU AI Act compliance
Applies to: Manufacturers
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Aug 2, 2027DeadlineEU
AI Act deadline for general-purpose AI models placed on the market before August 2, 2025
Providers of general-purpose AI models that were placed on the market before August 2, 2025 must take the necessary steps to comply with the obligations of the AI Act by August 2, 2027 (Article 111(3)). Models placed on the market from August 2, 2025 have had to comply since that date, and the Commission has been able to enforce the model obligations, including with fines under Article 101, since August 2, 2026.
Source: Regulation (EU) 2024/1689, consolidated text as of July 27, 2026, Article 111(3), EUR-Lex · Guide: EU AI Act compliance
Applies to: All industries
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Dec 2, 2027DeadlineEU
EU AI Act high-risk duties apply to credit scoring and to life and health insurance pricing
Under the Digital Omnibus, high-risk duties for stand-alone Annex III systems apply from December 2, 2027. They include AI that evaluates the creditworthiness of natural persons or establishes their credit score (fraud detection excluded) and AI for risk assessment and pricing in relation to natural persons in life and health insurance (Annex III points 5(b) and 5(c)).
Source: Regulation (EU) 2026/1744, EUR-Lex · Guide: EU AI Act compliance
Applies to: Banks and credit unions · Insurers
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Dec 2, 2027DeadlineEU
EU AI Act high-risk duties apply to AI used in recruitment and worker management
Regulation (EU) 2026/1744 sets December 2, 2027 as the date from which the AI Act's high-risk duties apply to systems listed in Annex III. Annex III point 4 covers AI for recruitment or selection, decisions on promotion or termination, allocating tasks based on individual behaviour or personal traits, and monitoring or evaluating performance. Article 26(7) requires employer deployers to inform workers' representatives and affected workers before use.
Source: Regulation (EU) 2026/1744, EUR-Lex · Guide: EU AI Act compliance
Applies to: Employers and HR
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Dec 2, 2027DeadlineEU
EU AI Act importer and distributor duties apply to stand-alone high-risk AI systems
From December 2, 2027, an EU importer must verify before placing an Annex III high-risk AI system on the market that it has passed conformity assessment, has technical documentation, carries the CE marking, and has an authorized representative, and must keep the certificate, instructions, and declaration of conformity for 10 years (Article 23). Distributors must check the CE marking and documentation (Article 24). An importer or distributor that rebrands or substantially modifies a high-risk system, or changes the intended purpose of a system so that it becomes high-risk, is treated as its provider (Article 25). For AI in Annex I Section A regulated products, the date is August 2, 2028; for AI systems classified as high-risk under Article 6(1) that relate to Annex I Section B products, including machinery, only Article 6(1), Article 60a, and Articles 102 to 112 apply (Article 2(2)), so Articles 23 to 25 do not apply to them.
Source: Regulation (EU) 2026/1744, EUR-Lex; AI Act Articles 23 to 25 · Guide: EU AI Act compliance
Applies to: Importers and exporters
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Dec 11, 2027DeadlineEU
Cyber Resilience Act applies in full to products with digital elements
The essential cybersecurity requirements and other obligations of Regulation (EU) 2024/2847 apply from December 11, 2027 to hardware and software products with a data connection made available in the EU. Products placed on the market before that date are covered only if substantially modified afterward, except for the reporting duty, which applies to them as well. A high-risk AI system that meets the Act's requirements is deemed to meet AI Act Article 15 cybersecurity requirements if its declaration of conformity demonstrates it.
Source: Regulation (EU) 2024/2847, Articles 12, 69, 71, EUR-Lex · Guide: EU AI Act compliance
Applies to: Manufacturers
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Jan 28, 2028DeadlineEU
Notified bodies under Annex I Section A product law must apply for AI Act designation
Article 43(3) of the AI Act, as amended by Regulation (EU) 2026/1744, gives notified bodies notified under Annex I Section A Union harmonisation legislation the power to assess high-risk AI systems against the Chapter III Section 2 requirements within the sectoral conformity assessment, provided their compliance with Article 31(4), (5), (10), and (11) was assessed in their existing notification, and, without prejudice to Article 28, requires them to apply for designation under Chapter III Section 4 by January 28, 2028.
Source: Regulation (EU) 2026/1744, Article 1(19), amending Article 43(3) of the AI Act, EUR-Lex · Guide: EU AI Act checklist by role
Applies to: Manufacturers · Hospitals and health systems
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Aug 2, 2028DeadlineEU
EU AI Act high-risk duties apply to AI in Annex I Section A regulated products
Chapter III, Sections 1 to 3 of the AI Act apply from August 2, 2028 to AI systems that are high-risk under Article 6(1) and Annex I: safety components of, or products under, listed EU harmonisation law that require third-party conformity assessment. For AI systems classified as high-risk under Article 6(1) that relate to Annex I Section B products, including machinery, only Article 6(1), Article 60a, and Articles 102 to 112 apply (Article 2(2)). For machinery, the AI requirements come instead through Machinery Regulation delegated acts, which shall apply by the same date.
Source: Regulation (EU) 2026/1744, Article 1(40), via AI Act Explorer · Guide: EU AI Act compliance
Applies to: Manufacturers · Hospitals and health systems
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Aug 2, 2030DeadlineEU
EU AI Act deadline for public-authority high-risk AI systems already on the market
Under Article 111(2) of the AI Act, as amended by Regulation (EU) 2026/1744, providers and deployers of high-risk AI systems intended to be used by public authorities that were placed on the market or put into service before the high-risk rules applied must take the necessary steps to comply with the requirements and obligations of the Regulation by August 2, 2030. A system placed on the market or put into service on or after the date the high-risk rules apply must comply when it is placed on the market or put into service. For other high-risk systems placed on the market or put into service before the date of application of Chapter III, the Regulation applies to their operators only if, from that date, the systems are subject to significant changes in their designs. Components of the large-scale IT systems listed in Annex X follow Article 111(1) instead, which requires those placed on the market or put into service before August 2, 2027 to be brought into compliance by December 31, 2030.
Source: Regulation (EU) 2024/1689, consolidated text as of July 27, 2026, Article 111(1) and (2), EUR-Lex · Guide: EU AI Act checklist by role
Applies to: All industries
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Jul 27, 2026LawEU
EU Digital Omnibus on AI enters into force, delaying high-risk AI Act duties
Regulation (EU) 2026/1744 moves stand-alone high-risk duties to December 2, 2027 and high-risk AI in regulated products to August 2, 2028. Prohibitions and general-purpose AI model duties are not delayed. Article 50 transparency duties apply from August 2, 2026, with a grace period to December 2, 2026 for the Article 50(2) marking duty on generative systems placed on the market before August 2, 2026. The regulation also moves the Machinery Regulation from Annex I Section A to Section B, which changes how much of the AI Act applies to AI in machinery.
Source: Regulation (EU) 2026/1744, EUR-Lex · Guide: EU AI Act compliance
Applies to: All industries
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Jul 27, 2026LawEU
Digital Omnibus moves machinery to Annex I Section B of the AI Act
Regulation (EU) 2026/1744 moves the Machinery Regulation from Annex I Section A to Section B, so only Article 6(1), Article 60a, and Articles 102 to 112 of the AI Act apply to AI systems that are high-risk under Article 6(1) as a safety component of machinery or as machinery itself. It requires Commission delegated acts adding health and safety requirements for high-risk AI systems to the Machinery Regulation, to apply by August 2, 2028.
Source: Regulation (EU) 2026/1744, EUR-Lex · Guide: EU AI Act compliance
Applies to: Manufacturers
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Jul 20, 2026GuidanceEU
Commission approves Article 50 transparency guidelines, to apply once formally adopted
The Commission approved the content of its Guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of the AI Act (C(2026) 5054 final), ahead of Article 50 applying on August 2, 2026. The approving Communication says the guidelines will be formally adopted at a later date, when all language versions are available, and will be applicable only from that moment. As of November 2, 2026, the Commission library page still offered only that Communication and its annex, dated July 20, 2026, although the page describes the guidelines as adopted. The Commission says they clarify the scope of application, relevant legal definitions, the transparency obligations, and the exceptions, and complement the Code of Practice on Transparency of AI-generated Content.
Source: European Commission, Guidelines on transparency obligations for providers and deployers of AI systems, July 20, 2026 · Guide: EU AI Act penalties and prohibited practices
Applies to: All industries
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Jul 8, 2026GuidanceEU
Commission finds Code of Practice on Transparency of AI-generated Content adequate
The voluntary Code of Practice on Transparency of AI-generated Content, drawn up under Article 50(7) of the AI Act and published on June 10, 2026, has a section for providers of generative AI systems on marking and detection of AI-generated and manipulated content and a section for deployers on labelling deepfakes and AI-generated and manipulated text. In an opinion of July 8, 2026 (C(2026) 4839 final), the Commission concluded that the Code adequately covers the obligations in Article 50(2), (4), and (5), and the AI Board adopted its adequacy assessment the next day. The Commission states that adherence to the Code does not constitute conclusive evidence of compliance with those obligations.
Source: European Commission, Commission opinion on the assessment of the Code of Practice on Transparency of AI-generated Content, July 9, 2026 · Guide: EU AI Act penalties and prohibited practices
Applies to: All industries
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Feb 6, 2025GuidanceEU
Commission approves guidelines on the definition of an AI system under the AI Act
The Commission approved the content of its guidelines on the definition of an AI system under Article 3(1) of the AI Act on February 6, 2025 (C(2025) 924 final), stating that the guidelines would be applicable only once formally adopted. It formally adopted them on July 29, 2025, as Communication C(2025) 5053 final. The guidelines say they are not binding and that any authoritative interpretation of the AI Act may ultimately only be given by the Court of Justice of the European Union. They predate the Digital Omnibus on AI.
Source: European Commission, Commission guidelines on the definition of an AI system, February 6, 2025 · Guide: EU AI Act compliance
Applies to: All industries
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Feb 4, 2025GuidanceEU
Commission approves guidelines on prohibited AI practices under the AI Act
The Commission approved the content of its guidelines on prohibited AI practices under Article 5 of the AI Act on February 4, 2025 (C(2025) 884 final), stating that the guidelines would be applicable only once formally adopted. It formally adopted them on July 29, 2025, as Communication C(2025) 5052 final. The guidelines say they are non-binding and that any authoritative interpretation of the AI Act may ultimately only be given by the Court of Justice of the European Union. They predate the Digital Omnibus on AI.
Source: European Commission, Commission publishes the Guidelines on prohibited artificial intelligence (AI) practices, as defined by the AI Act, February 4, 2025 · Guide: EU AI Act penalties and prohibited practices
Applies to: All industries
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Feb 2, 2025DeadlineEU
EU AI Act prohibited practices and AI literacy duty apply
Chapters I and II of Regulation (EU) 2024/1689 apply from February 2, 2025 (Article 113(a)), including the definitions, the Article 4 AI literacy duty, and the Article 5 prohibited practices. The two prohibitions later added by Regulation (EU) 2026/1744 apply from December 2, 2026. As adopted, Article 4 required providers and deployers to take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf. As amended by Regulation (EU) 2026/1744, it requires providers and deployers to take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, and states that this obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.
Source: Regulation (EU) 2024/1689, Articles 4, 5, and 113, EUR-Lex · Guide: EU AI Act penalties and prohibited practices
Applies to: All industries