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Independent Cross-Jurisdictional ReviewEU AI Act Timeline · Global DeskUpdated 14 June 2026
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EU AI Act and Digital Omnibus Timeline: What Applies When

One dated, current view of every EU AI Act milestone, the Digital Omnibus deferral, and the obligations that sit alongside them. Each entry records the obligation, who it binds, the governing article, and whether it is in force, adopted, or only proposed. Sourced from primary regulatory texts. Reviewed monthly and on legislative events.

Last updated 14 June 2026. Verified against primary sources. The single contested point is the high-risk deadline: legally 2 August 2026 today, with a proposed deferral to 2 December 2027 not yet adopted.

Short answer

As of 14 June 2026, the EU AI Act applies in stages. In force now: the Article 5 prohibited-practices ban and the Article 4 AI literacy duty (both since 2 February 2025), and the general-purpose AI (GPAI) model obligations, the governance architecture, and the Article 99 penalties framework (all since 2 August 2025).

The next binding date is 2 August 2026: Article 50 transparency obligations apply, and, on the current law, high-risk standalone systems under Annex III. The Digital Omnibus on AI reached a provisional political agreement on 7 May 2026 that would move the high-risk date to 2 December 2027 (and Annex I product-embedded systems to 2 August 2028), but it is not yet adopted and not published in the Official Journal, so the original 2 August 2026 and 2 August 2027 dates remain the law. The revised Product Liability Directive applies to products placed on the market after 9 December 2026.

What changed recently

The moving parts since spring 2026, most recent first.

  • June 2026 The European Commission issued guidance and a Code of Practice on the Article 50 transparency obligations (chatbot disclosure, deepfake and AI-content labelling), confirming the core duty proceeds on 2 August 2026.
  • 7 May 2026 Council and Parliament reached a provisional political agreement on the Digital Omnibus on AI. It would defer high-risk Annex III to 2 December 2027 and Annex I to 2 August 2028, using fixed dates rather than the Commission's earlier conditional stop-the-clock trigger. Not yet adopted, not yet in the Official Journal.
  • Status today Because the Omnibus is not law, the binding high-risk date is still 2 August 2026. Article 50 transparency is also confirmed for 2 August 2026 and is not deferred. Treat 2 December 2027 as a proposal, not a settled deadline, until publication.
  • 19 Nov 2025 The Commission published the Digital Omnibus package, opening the proposal to postpone the high-risk compliance deadline.
4
In force
Applying and enforceable today
2
Binding next
2 Aug 2026 and 2 Aug 2027, unless deferred
1
Adopted, pending
Product Liability Directive, 9 Dec 2026
1
Proposed only
Digital Omnibus deferral, not adopted
1 August 2024 In force
Entry into force

The AI Act enters into force

Regulation (EU) 2024/1689 entered into force, starting the staged application calendar. Nothing became immediately binding on operators on this date; the obligations switch on at the milestones below.

ObligationStarts the compliance clock. No operator duties yet.
Who it bindsNo one operationally on this date.
Legal basisRegulation (EU) 2024/1689, Article 113
2 February 2025 In force
Six months on

Prohibited practices and AI literacy apply

The first hard obligations took effect. The Article 5 ban on prohibited AI practices (including untargeted facial-image scraping, certain social scoring, manipulative or exploitative systems, and most real-time remote biometric identification in public spaces) applies. Separately, the Article 4 AI literacy duty requires providers and deployers to ensure a sufficient level of AI literacy among staff and others operating AI on their behalf.

ObligationStop prohibited practices. Ensure staff AI literacy.
Who it bindsAll providers and deployers placing or using AI in the EU.
Legal basisArticles 5 and 4
Status note. Both remain in force. The Digital Omnibus proposes to soften the Article 4 wording (a duty to support AI literacy rather than guarantee a specific level), but that softening is not adopted. The Article 4 obligation as written still applies.
2 August 2025 In force
Twelve months on

GPAI model obligations, governance, and penalties apply

Three things switched on. The general-purpose AI (GPAI) model obligations under Chapter V apply: technical documentation, training-data summaries, copyright policy, and, for models with systemic risk, model evaluation and serious-incident reporting. The governance architecture became operational, with the European AI Office coordinating GPAI and systemic-risk supervision alongside the AI Board, scientific panel, and advisory forum. The Article 99 penalties framework applies, requiring Member States to lay down penalty rules.

ObligationGPAI documentation and (systemic-risk) evaluation. Penalty rules in national law.
Who it bindsProviders of GPAI models; Member States; the AI Office for supervision.
Legal basisChapter V; Articles 51 to 56; Article 99
Penalty exposure. Article 99 caps: up to EUR 35 million or 7% of worldwide annual turnover for Article 5 breaches; up to EUR 15 million or 3% for most other breaches; up to EUR 7.5 million or 1% for incorrect or misleading information. Enforcement of penalties against GPAI providers begins 2 August 2026.
6 August 2025 In force (guidance)
Insurance-sector context

EIOPA Opinion on AI governance for insurers

EIOPA published its Opinion on Artificial Intelligence governance and risk management (reference EIOPA-BoS-25-360), addressed to national insurance supervisors. It creates no new rules. It reads AI into existing sectoral law (Solvency II, the Insurance Distribution Directive, DORA, and the GDPR) on a risk-based, proportionate basis, covering data governance, fairness, explainability, and human oversight across pricing, underwriting, claims, and fraud detection. Relevant context for any insurer deploying AI agents.

ObligationInterpretative guidance, not a new rule. Apply AI within existing sectoral law.
Who it bindsNational insurance supervisors; persuasive for insurers and intermediaries.
Legal basisEIOPA-BoS-25-360 (supervisory opinion)
2 August 2026 Binding now (deferral proposed for high-risk only)
Twenty-four months on

Transparency, and on current law high-risk standalone systems

Two distinct things land on this date, and they have different statuses.

Article 50 transparency (not deferred). Disclosure that a person is interacting with an AI system, labelling of AI-generated or manipulated content including deepfakes, and notice for emotion-recognition and biometric-categorisation systems. The Digital Omnibus does not move this date. It proposes only a narrow grace period to 2 December 2026 for the machine-readable marking or watermarking duty under Article 50(2), and only for systems already on the market.

High-risk standalone systems (deferral proposed, not adopted). On the current law, the full obligations for Annex III high-risk systems (risk management, data governance, technical documentation, logging, human oversight, accuracy and robustness, conformity assessment, registration) apply from this date. The Digital Omnibus would move this to 2 December 2027.

ObligationArticle 50 transparency. Plus, on current law, the full Annex III high-risk regime.
Who it bindsProviders and deployers of AI with transparency duties; providers and deployers of Annex III high-risk systems.
Legal basisArticle 50; Article 6(2) and Annex III; Chapter III
The contested point. Until the Digital Omnibus is adopted and published in the Official Journal, 2 August 2026 is the binding high-risk date. Plan against it. Treat 2 December 2027 as a proposed deferral, covered in the next entry. Article 50 transparency proceeds on 2 August 2026 regardless.
Digital Omnibus on AI Proposed, not adopted
Provisional agreement 7 May 2026

The deferral package: proposed dates, not yet law

The Commission published the Digital Omnibus package on 19 November 2025 to postpone the high-risk compliance deadlines. On 7 May 2026, the Council and Parliament reached a provisional political agreement. The agreement replaced the Commission's earlier conditional stop-the-clock trigger (which would have tied the deadline to harmonised standards being available) with fixed dates:

High-risk Annex III standalone systems would move from 2 August 2026 to 2 December 2027. High-risk Annex I product-embedded systems would move from 2 August 2027 to 2 August 2028.

What it doesPostpones high-risk deadlines to fixed later dates.
StatusProvisional political agreement only. Not formally adopted, not in the Official Journal.
If adoptedEnters into force three days after OJ publication. Adoption expected before 2 Aug 2026, not guaranteed.
Do not treat as settled. The provisional agreement must still be formally adopted by the Council and Parliament and published in the Official Journal before it has any legal effect. Until then the original dates (2 August 2026 and 2 August 2027) are the law. This page will be updated on adoption.
9 December 2026 Adopted, applies from this date
Product liability

Revised Product Liability Directive applies; PLD transposition due

Directive (EU) 2024/2853, the revised Product Liability Directive, applies to products placed on the market or put into service after 9 December 2026, and Member States must have transposed it into national law by the same date. It expressly treats software and AI systems as products, introduces rebuttable presumptions of defectiveness that ease a claimant's burden of proof where a system is complex or opaque, and expands compensable damage to include data loss and medically recognised psychological harm. The old Directive 85/374/EEC continues to apply to products placed on the market before this date. Free and open-source software supplied outside a commercial activity is excluded.

A separate, narrower point: the Digital Omnibus proposes a grace period to 2 December 2026 for the Article 50(2) machine-readable marking or watermarking duty, for systems already on the market only. The core Article 50 transparency duty is unaffected and still applies from 2 August 2026.

ObligationStrict product liability for defective products, expressly including AI and software.
Who it bindsManufacturers, importers, and in some cases providers of AI and software placed on the EU market after the date.
Legal basisDirective (EU) 2024/2853 (revised Product Liability Directive)
2 August 2027 Binding now (deferral to 2028 proposed)
Thirty-six months on

High-risk systems embedded in regulated products

On the current law, the high-risk obligations apply to AI systems that are safety components of, or are themselves, products already regulated under the Union harmonisation legislation listed in Annex I (for example medical devices, machinery, lifts, radio equipment, and motor vehicles). These systems get the extra year because their conformity assessment runs through existing sectoral product law. The Digital Omnibus proposes to move this date to 2 August 2028.

ObligationFull high-risk regime for Annex I product-embedded AI, via existing sectoral conformity assessment.
Who it bindsProviders and deployers of high-risk AI embedded in Annex I regulated products.
Legal basisArticle 6(1) and Annex I
Status note. 2 August 2027 is the binding date today. The proposed Digital Omnibus deferral to 2 August 2028 is not yet adopted.
31 December 2030 Set by the Regulation
Long-stop

Legacy large-scale IT systems

High-risk AI components of the large-scale EU information systems listed in Annex X (for example systems in the area of freedom, security, and justice) that were placed on the market or put into service before 2 August 2027 must be brought into compliance by 31 December 2030. This is the long-stop transitional date in the Regulation and is not affected by the Digital Omnibus deferral.

ObligationBring legacy Annex X high-risk components into compliance.
Who it bindsOperators of the large-scale IT systems listed in Annex X.
Legal basisArticle 111(2) and Annex X
Editorial Firewall Active

How this timeline is maintained

Every date is verified against primary regulatory texts (the Official Journal, the consolidated Regulation, supervisory authority publications) before it is stated. Where a date is contested, both the legally binding date and the proposed change are shown, with the status of each made explicit. The page leads with the binding date and never presents a proposed deferral as settled.

The timeline is reviewed monthly and on legislative events, including any formal adoption and Official Journal publication of the Digital Omnibus. The date in the utility bar and the last-updated stamp reflect the most recent review. No government, regulator, law firm, or operator pays for placement. Corrections may be submitted to [email protected] and are reviewed against primary sources before adoption.

Primary sources

Related reading on this desk: the global AI regulatory tracker across 17 jurisdictions, and the US, EU, and UK AI liability comparison.

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