Which deadline applies to us first?

The prohibitions and the AI literacy duty, which have applied since 2 February 2025 — they bind everyone, regardless of what you build. After that it depends on your role: providers of general-purpose AI models are on the 2 August 2025 date, most high-risk obligations land on 2 August 2026, and high-risk AI embedded in products regulated under other EU legislation follows on 2 August 2027.

Do the dates apply to systems already in use?

The phase-in structure exists precisely because systems already on the market cannot be re-engineered overnight. What it does not do is pause the prohibitions: a practice in the banned list had to stop from 2 February 2025 whether the system was new or years old.

Is 2 August 2026 the real deadline for most companies?

For most organisations, yes. That is when the bulk of the regulation applies, including the Annex III high-risk obligations that catch ordinary business uses such as recruitment, credit scoring and insurance pricing. Working back from it, a documentation package, conformity assessment and registration entry are not a one-quarter project.

What does 2 August 2027 cover?

The extended transition for high-risk AI embedded in products already regulated under other EU legislation — the Annex I route. Those products follow their existing conformity assessment cycles, so the AI Act gives them an extra year beyond the general high-risk date.

What should we do if we are behind?

Start with the inventory and the classification, because every other task depends on knowing which systems you hold and which band they sit in. Then close the prohibited-practice question immediately, since that obligation is already live, and sequence the rest against the date that applies to each system.

AI Act

AI Act key dates and deadlines

The AI Act does not switch on all at once. It arrives in five steps between August 2024 and August 2027, and the step that matters to you depends on what you build and how it is classified. The sequence rewards organisations that treat the inventory and classification as the first task rather than the last.

The timeline in 60 seconds

In force: 1 August 2024. The regulation entered into force; the obligations then phase in over three years.
Already applying: Prohibitions and the AI literacy duty since 2 February 2025; GPAI obligations, governance structures and penalty provisions since 2 August 2025.
The big one: 2 August 2026 — the bulk of the regulation, including the Annex III high-risk obligations.
Last stop: 2 August 2027, when the extended transition ends for high-risk AI embedded in Annex I regulated products.

The five dates

1 August 2024
Entry into force
The AI Act becomes law. Nothing is enforceable yet, but the classification rules that everything else depends on are fixed from this point.
What to do
- Build the inventory of AI systems you develop, buy, embed or use.
- Record the role you occupy for each system: provider, deployer, importer or distributor.
2 February 2025
Prohibitions and AI literacy apply
The unacceptable-risk practices are banned, and organisations must ensure a sufficient level of AI literacy among the staff who deal with AI systems on their behalf.
What to do
- Screen every system against the prohibited practices and stop anything that matches.
- Give the teams that build or operate AI systems training proportionate to their role, and keep a record of it.
2 August 2025
GPAI, governance and penalties apply
Obligations for general-purpose AI models take effect, the governance structures are operational, and the penalty provisions apply.
What to do
- If you provide a GPAI model: technical documentation, information for downstream providers, a copyright policy and a training-data summary.
- If you build on top of someone else's model: obtain the provider's documentation and keep it with your own file.
2 August 2026
The bulk of the regulation applies
Most remaining obligations take effect, including the Annex III high-risk requirements and the transparency duties.
What to do
- Complete the requirement set for each high-risk system: risk management, data governance, Annex IV documentation, logging, human oversight, accuracy and cybersecurity.
- Finish conformity assessment, apply the CE marking and register the system in the EU database.
- Deployers: assign oversight, brief affected workers and complete a fundamental rights impact assessment where one is required.
2 August 2027
Extended transition ends
The additional transition period closes for high-risk AI embedded in products regulated under other EU legislation — the Annex I route.
What to do
- Align the AI Act requirements with the product's existing conformity assessment cycle rather than running two parallel processes.
- Confirm with suppliers of embedded AI components that their documentation supports your assessment.

Working backwards from your date

The dates are fixed; the work is not evenly distributed behind them. A high-risk system facing 2 August 2026 needs its risk management process, data governance evidence and Annex IV documentation in place well before the conformity assessment and registration steps, because those depend on the documentation being finished. A GPAI provider is already past its date and should be maintaining, not drafting, its documentation set.

Anyone unsure which date applies should go back to the risk classification: the risk level and the route into high-risk determine the deadline, not the industry the company sits in. Two dates are already behind us — the prohibited practices ban and the AI literacy duty from February 2025, and the GPAI rules of the AI Act from August 2025.

Frequently asked questions

Sources

EUR-Lex — Regulation (EU) 2024/1689 (Artificial Intelligence Act)

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AI Act key dates and deadlines

The timeline in 60 seconds

The five dates

Entry into force

Prohibitions and AI literacy apply

GPAI, governance and penalties apply

The bulk of the regulation applies

Extended transition ends