High-risk obligations apply in
2 Dec 2027
On 2 December 2027, the core obligations for Annex III high-risk systems switch on for deployers. That date was pushed back from 2 August 2026 by the 2026 Digital Omnibus, and the nearer milestone, 2 August 2026, brings the Article 50 transparency duties. The work to be ready is not small, and it is far easier to start now than to scramble at the end.
The full timeline
02 Feb 2025IN FORCE
AI literacy & prohibited practices
Article 4 AI literacy duty and Article 5 prohibitions apply.
Art. 4 · Art. 5
02 Aug 2025IN FORCE
GPAI & governance
General-purpose AI model obligations and governance provisions apply.
Ch. V
02 Aug 202626 days
Transparency obligations
Article 50 transparency duties apply, such as disclosing AI interactions and labelling AI-generated content. Article 4 AI literacy is already in force.
Art. 50
02 Dec 20272 Dec 2027
High-risk system obligations
The core deployer obligations for Annex III high-risk systems apply. Postponed from 2 August 2026 by the 2026 Digital Omnibus.
Annex III
02 Aug 2028757 days
Embedded high-risk systems
High-risk systems that are safety components of regulated products. Postponed from 2 August 2027 by the 2026 Digital Omnibus.
Annex I
02 Aug 20301,487 days
Legacy systems
Systems placed on the market before the Act, in certain cases.
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