AI Act after the Omnibus: the applicable deadlines
AI transparency duties apply from August 2026. High-risk systems have different application dates under Annex III and Annex I.
Contents
The AI Act has several application dates, rather than one deadline for every system. The consolidated version dated 27 July 2026 distinguishes different phases. The original July report described the beginning of August as an event that had already happened and did not identify the applicable provisions.
Phases already reached
The regulation entered into force on 1 August 2024. General provisions, including AI literacy, and the relevant prohibitions apply from 2 February 2025. General-purpose model rules have their own phase from 2 August 2025 and transition arrangements for older models. Article 50 transparency obligations apply from 2 August 2026.
Entry into force and the application of a particular duty are different events. The first does not prove that every provider or deployer obligation became applicable on that date.
High-risk dates differ
Article 113(c) sets 2 December 2027 for the relevant high-risk rules concerning Article 6(2) and Annex III systems. It sets 2 August 2028 for Article 6(1) and Annex I systems. Classification matters; a blanket statement that all high-risk duties apply from August 2026 is outdated.
Existing systems and models have additional conditions in Article 111. For example, providers of synthetic-content systems placed on the market before 2 August 2026 have until 2 December 2026 to comply with Article 50(2). That transition does not automatically postpone other obligations.
Turning dates into an implementation plan
Our proposed working method is to record each system’s purpose, the organisation’s role, classification, relevant provision, market or service entry date and applicable transition. Only then assign a deadline and an accountable owner. Keep evidence of readiness, such as the actual user notice or relevant system documentation.
This is an orientation to the current primary text. A particular classification can require a closer assessment of the purpose and deployment circumstances.
Correction and update, 12 October 2026: The original report confused some dates and overstated legal obligations. This version follows the current consolidated regulation and the primary materials linked below. The original publication date is retained.
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