What it is

Regulation (EU) 2024/1689 — the European Union’s comprehensive, risk-tiered AI law. In force August 1, 2024, with binding obligations phased in across a four-year window.

Who it covers

Providers, deployers, importers, and distributors of AI systems in the EU — including non-EU firms whose AI output is used in the EU. The extraterritorial reach surprises many US-headquartered companies.

Enforcement calendar (split)

The single most-confused fact about the EU AI Act: the deadlines do not all fall on the same date.

| Date | What kicks in | |---|---| | Feb 2, 2025 | Prohibited-practice ban (Article 5) | | Aug 2, 2026 | Article 50 transparency obligations + GPAI provider enforcement | | Dec 2, 2027 | High-risk obligations for Annex III systems (delayed from Aug 2026) | | Aug 2, 2028 | High-risk obligations for Annex I systems embedded in regulated products |

If you read a summary that says “the AI Act takes effect August 2026,” it is conflating the transparency/GPAI phase with the high-risk phase. They are now 16 months apart.

What’s required (high-risk systems)

Practitioner readiness baseline:

  1. AI inventory complete and classified against Annex III
  2. Risk management system operational (Article 9)
  3. Data governance and training-data documentation (Article 10)
  4. Technical documentation (Article 11) and record-keeping (Article 12)
  5. Human oversight (Article 14) and accuracy/robustness (Article 15)
  6. Quality management system (Article 17) and post-market monitoring (Article 72)
  7. Conformity assessment completed and EU declaration filed

What’s required (GPAI providers)

Separate stack, enforced from Aug 2, 2026:

  • Technical documentation of the model (Annex XI)
  • Downstream-deployer information package (Annex XII)
  • Copyright policy and training-data summary
  • Systemic-risk evaluations for models above the 10^25 FLOP compute threshold

The voluntary GPAI Code of Practice is the operational on-ramp; signatories get a presumption of conformity.

Penalties

Up to €35 million or 7% of global annual turnover, whichever is higher, for prohibited-practice violations. Up to €15M or 3% for most other infringements.

What to watch

  • AI Office guidance on GPAI scope and systemic-risk thresholds
  • Delegated and implementing acts on conformity assessment for Annex III
  • Coordinated enforcement across national supervisory authorities