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Status update · reviewed

EU AI Act — Implementation timeline status update

EU policymakers are discussing possible modifications to parts of the AI Act implementation timeline. Until any change is formally adopted by the Council and Parliament, the original deadlines under Regulation (EU) 2024/1689 remain legally binding. This page tracks what is in formal force, what is being discussed, and what SMEs should do now.

What is legally in force today

  • 2 February 2025 — Article 4 (AI literacy): Providers and deployers must ensure their staff have a sufficient level of AI literacy. Already in force; not part of any current postponement discussion.
  • 2 February 2025 — Article 5 (prohibited practices): Eight categories of prohibited AI practices are unlawful. Already in force; not part of any current postponement discussion.
  • 2 August 2025 — Article 53 (GPAI obligations): Providers of general-purpose AI models face transparency, copyright, and (for systemic-risk models) safety obligations. Already in force.
  • 2 August 2026 — Article 6 + Annex III (high-risk AI obligations): Providers and deployers of Annex III high-risk AI systems must complete conformity assessment, technical documentation, risk management, and EU-database registration. This date remains legally binding as of the review date above.
  • 2 August 2027 — Annex I high-risk (legacy): AI systems embedded in already-regulated products (machinery, medical devices, etc.) reach full applicability.

What is being discussed

EU institutions are openly discussing simplification packages for parts of the digital regulatory acquis — informally referred to in press coverage as the “Digital Omnibus.” Reported topics include possible postponements for specific AI Act obligations, lighter administrative regimes for small providers, and clarifications on scope. The shape, scope and timing of any such change are not finalised and not legally binding at the date this page was last reviewed.

EuroComply deliberately does not commit this page to specific delay durations before formal adoption. Once the Council formally adopts any amendment to Regulation (EU) 2024/1689 and the act is published in the Official Journal, this page will be updated to cite the published act, the new dates, and the affected scope. Until then, treat any specific number you see in third-party coverage as a forecast, not a fact.

What SMEs should do now

  1. Keep preparing on the original timeline. The risk-adjusted cost of pausing is higher than the cost of completing preparation that turns out to have been on a slower deadline.
  2. Lock in AI inventory + Annex III classification this quarter. These are the gating inputs to every downstream task and are not affected by any postponement discussion.
  3. Complete Article 4 (AI literacy) training now. It is already in force; non-compliance is a current enforcement risk, not a future one.
  4. Track formal adoption, not press signal. The trigger to revise your plan is publication in the Official Journal, not a press release or political-agreement headline.
  5. Bookmark this page and the official EU AI Office service desk. EuroComply updates this status as authoritative sources land.

FAQ

Is the 2 August 2026 EU AI Act deadline still binding?

Yes. As of the date this page was last reviewed, the 2 August 2026 deadline for high-risk AI obligations under Article 6 and Annex III of Regulation (EU) 2024/1689 remains the legally binding date. Any change to this date only takes effect once formally adopted by the Council and Parliament and published in the Official Journal.

What about Article 4 (AI literacy), Article 5 (prohibitions), and GPAI obligations?

These provisions are already in force. Article 4 (AI literacy) has applied since 2 February 2025. Article 5 prohibitions have applied since 2 February 2025. Article 53 obligations for general-purpose AI models have applied since 2 August 2025. None of these are part of the current implementation-timeline discussions.

Should we keep preparing for 2 August 2026?

Yes. Until any change is formally adopted, SMEs deploying or providing high-risk AI systems should continue to prepare on the original timeline: AI inventory, Annex III classification, Annex IV technical documentation, conformity assessment, EU-database registration. Pausing preparation creates execution risk that exceeds the upside of a possible postponement.

Where can I track the official status?

Authoritative sources: the European Commission's AI Office, EUR-Lex (for the published regulation and any official amending acts), and the Council of the EU's press releases. Public legal analysis from established firms (Bird & Bird, Travers Smith, OneTrust, IAPP) tracks unofficial signals before formal adoption.

Why does this page not commit to specific delay durations?

Because committing to specific durations before formal adoption creates more harm than information. Once the Council formally adopts any amendment to Regulation (EU) 2024/1689, this page will be updated to cite the published act, the new dates, and the affected scope. Until then, EuroComply does not publish unverified specifics.

Authoritative sources

Last reviewed: . Maintained by EuroComply. Editorial policy.

For informational purposes only. This is not legal advice — consult qualified legal counsel for your specific compliance situation. The status of EU institutional discussions is evolving; verify current status before relying on any specific date.