The EU AI Act timeline
The AI Act does not apply all at once. Most of it already binds you; the rest arrives on set dates to 2028. This is the plain-English time-map — what applies, from when, to whom, and what each duty actually requires, with examples. Written for the people who have to act on it.
Regulation (EU) 2024/1689 · current as at 03-08-2026 · as amended by Regulation (EU) 2026/1744, in force 27-07-2026
The short version.
Most of the AI Act already applies to you — its general application date, 2 August 2026, has passed. The heaviest duties arrive in steps through 2028. A recent amending act, the Digital Omnibus on AI (Regulation (EU) 2026/1744, in force since 27 July 2026), deferred the principal deadline to December 2027 — and, in the same act, added new prohibitions that apply sooner. Below is the whole map, and where it touches your organisation.
What applies, from when, and to whom.
Read it as a calendar of duties. For each date: who it binds, what it requires, and an example you will recognise.
- 2 Feb 2025 Applies todayWhoEvery organisation that uses AI at work — any sector, any size.WhatTwo duties. The prohibited uses of AI may not be used at all. And the AI-literacy duty: you must take measures to support the development of AI literacy among the people who operate AI on your behalf. Regulation (EU) 2026/1744 clarified that this is an obligation of effort — you are not required to guarantee any particular level of AI literacy in any individual.For exampleYou may not run emotion-recognition on staff, or rank people through “social scoring”. And an HR team using a CV-screening tool should be equipped to read its output critically — not treat it as a verdict.
- 2 Aug 2025 Applies todayWhoTwo audiences: the makers of the large AI models — and, through the penalties, you.WhatThe large “foundation” models behind tools like ChatGPT or Claude carry transparency and documentation duties. And the penalty rules become applicable: each Member State has to have designated who enforces the Act and what the sanctions are.For exampleThe model-maker must publish a summary of its training data. For you, the point is simpler: from this date the Act is enforced by named national authorities.
- 2 Aug 2026 Applies todayWhoEveryone in scope. This was the Act’s general application date — and it has now passed.WhatThe bulk of the Regulation became applicable. The Article 50 transparency duties: people must be told when they are dealing with an AI system, and AI-generated or manipulated content must be disclosed as such. The enforcement architecture applies in full, and the European Commission may now fine the providers of general-purpose AI models.For exampleA customer-service chatbot has to make clear it is not a person. A synthetic image or video your organisation publishes has to be disclosed as AI-generated.
- 2 Dec 2026 Coming — added by the OmnibusWhoProviders of generative AI — plus a new prohibition that binds everyone.WhatA new prohibition on AI that creates non-consensual intimate imagery or child sexual abuse material (the “nudifier” applications). And the end of a four-month transitional window: generative-AI systems already placed on the market before 2 August 2026 must by this date mark their output in machine-readable form, as Article 50(2) requires.For exampleA tool that fabricates fake nude images of real people is prohibited outright. And the content-generation tool your team already uses has to mark what it produces as AI-made — the duty sits with whoever supplies it.
- 2 Dec 2027 Coming — the principal date for employersWhoProviders and deployers of “high-risk” AI: recruitment, performance management, access to credit, education and essential services.WhatThe substantial obligations. If you deploy such a system: keep a competent human in control, run a fundamental-rights impact assessment (a documented check of who the system could unfairly affect), keep logs, and use it only as intended. Providers — those who build, brand or substantially change the system — add formal conformity checks (a CE-style sign-off) and registration in an EU database.For exampleIf you use AI to screen, rank or score job candidates, this is the date your governance has to be in place. Note the consequence: the system you deploy today is the one you will have to prove compliant then.
- 2 Aug 2028 ComingWhoMakers of regulated products with AI inside — machinery, medical devices, toys, lifts and the like.WhatThe same high-risk obligations, for AI built into products already regulated under other EU law.For exampleA scanner that uses AI to flag tumours: the maker must meet the high-risk rules before the device can be placed on the market.
Two questions decide how much of the high-risk row applies to you: is your system actually high-risk, and are you its provider or its deployer? Both are easier to get wrong than you would think — see deployer or provider? and the AI Act, explained.
The Digital Omnibus on AI, in one idea.
You will see the Digital Omnibus on AI referred to above. It does not replace the AI Act: it is an amending Regulation — a bundle of edits the EU packaged together. It is now law. Regulation (EU) 2026/1744 was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026. Two kinds of edit matter to you.
It deferred some deadlines.
More time to put the same governance in place — not less governance to build.
And it added new duties.
The same act created obligations that did not exist before: a new prohibition on AI “nudifier” and CSAM tools from December 2026, and a new four-month transitional window — to 2 December 2026 — for generative-AI systems already on the market to meet the machine-readable marking duty in Article 50(2). It also gave Member States until 2 August 2027 to have at least one national AI regulatory sandbox operational. So the Omnibus is not simply relief: it both defers and expands.
These are obligations, not guidance.
The duties on this page are legal obligations, and they carry fines — set as a share of worldwide annual turnover. The penalty rules have been applicable since August 2025, and since 2 August 2026 the enforcement architecture applies in full: each penalty becomes enforceable once the duty it supports applies.
They run alongside the GDPR (which reaches 4%), not instead of it. But for most employers the sharper cost is commercial — the contract that stalls, the client question you cannot answer — long before any penalty is imposed.
Primary sources: Regulation (EU) 2024/1689, esp. Articles 4, 50, 57 and 113; Regulation (EU) 2026/1744 (the Digital Omnibus on AI), OJ 24-07-2026, in force 27-07-2026; the European Commission (digital-strategy.ec.europa.eu) and the Council of the EU. Current as at 03-08-2026.
A date on a calendar is not a compliance plan.
Knowing the map is step one. The work is turning it into a plan for your systems — and having the evidence to show for it. Three questions decide what actually applies to you:
Is any of your AI high-risk? Start with the AI Act, explained.
Are you a provider or a deployer? It flips more easily than you think — deployer or provider?
You sit in HR — what does this mean for hiring and people decisions? See AI for HR.
That is exactly what we facilitate: we map your systems against this calendar, tell you what you must do and by when, and help you build the evidence — so the deadline is a plan, not a worry.
Which of these dates already has your name on it?
Bring the AI systems you are weighing up. We’ll tell you, plainly, which dates have your name on them.
Book Kramer Consulting →Related guides
The EU AI Act, explained
Heard of it, hazy on the detail? Grasp it through two laws you may already know — GDPR and product-safety regulation.
Read the guide TransparencyWho has to label AI content, and when
Since 2 August 2026 the AI Act’s transparency obligations have been applicable in full — and unlike the high-risk rules, they were not deferred. The operational guide: four duties, two roles, five exceptions, and how to tell which are yours. What a deep fake actually is, what is permitted and on what condition, and why the visible label on your published video is your job and not your vendor’s.
Read the guide Provider or deployerDeployer or provider?
Most companies using AI are “deployers”, with manageable duties. But configure, rebrand or repurpose that AI and the Act can treat you as its “provider” — with a manufacturer’s full obligations. The line, and how not to cross it by accident.
Read the guide