AI Act

The AI Act: timeline and obligations for companies - what applies in 2026 and what comes after the Digital Omnibus (2027-2028)

The Artificial Intelligence Regulation (2024/1689) did not start applying on a single day - it comes into force in stages spread over 2025-2028. That is good news and bad news at the same time: some obligations already apply to you (since 2 August 2026 that includes the transparency obligations under Art. 50), and Regulation 2026/1744 - the Digital Omnibus on AI - pushed high-risk systems back to 2 December 2027 and 2 August 2028.

Update, 24 September 2026This article was written in July 2026, when the obligations for high-risk systems were due to apply from 2 August 2026. Regulation (EU) 2026/1744 (the Digital Omnibus on AI, in force since 27 July 2026) postponed them: Annex III to 2 December 2027, Annex I to 2 August 2028. The transparency obligations under Art. 50 applied as planned on 2 August 2026. The Omnibus also softened the wording of the AI literacy obligation in Art. 4 - the description below reflects that change. The dates in the text have been corrected; you will find the current calendar with countdowns in the Regulatory radar.
Key takeaways
  • The AI Act (Regulation 2024/1689) comes into force in stages spread over 2025-2028, not on a single day.
  • The transparency obligations under Art. 50 - including informing people they are dealing with AI and labelling synthetic content - have applied since 2 August 2026.
  • The Digital Omnibus (Regulation 2026/1744) postponed the high-risk obligations: Annex III to 2 December 2027, Annex I to 2 August 2028.
  • The AI literacy obligation under Art. 4 has applied since 2 February 2025 and was not postponed by the Digital Omnibus.
  • Prohibited practices under Art. 5 carry fines of up to EUR 35 million or 7% of worldwide turnover.

Why this timeline?

The AI Act entered into force on 1 August 2024, but the EU legislator staggered the application of its individual chapters over time. The logic is simple: first the most dangerous things (prohibited practices), then the foundations (general-purpose models, supervision), and last the most operationally demanding package - high-risk systems.

What already applies under the AI Act? (as of September 2026)

From 2 February 2025: prohibited practices and AI literacy

From 2 August 2025: GPAI models and the supervisory architecture

2 August 2026: transparency obligations (Art. 50) and most of the Regulation

From that date the bulk of the Regulation's remaining provisions applies - with one important exception: the package for high-risk systems under Annex III (including AI in recruitment and workforce management, creditworthiness assessment, education, access to public services) was postponed by Regulation 2026/1744 to 2 December 2027. The list of obligations has not changed, only the deadline has.

If your system falls into this category, the list of obligations is long:

Important: it is not only providers who have obligations. Deployers of high-risk systems are responsible, among other things, for using the system in accordance with its instructions, human oversight and monitoring its operation - and in some cases for a fundamental rights impact assessment (FRIA).

What does apply from 2 August 2026 without any postponement: the transparency obligations under Art. 50 - including informing users that they are interacting with AI, and labelling generated content and deepfakes. For systems placed on the market before that date, the transitional period for marking synthetic content (Art. 50(2)) ends on 2 December 2026.

What did the Digital Omnibus change in the AI Act timeline? (2 December 2027 and 2 August 2028)

The Digital Omnibus on AI (Regulation 2026/1744, in force since 27 July 2026) split the high-risk package across two deadlines. 2 December 2027 - stand-alone systems under Annex III. 2 August 2028 - AI systems that are a product, or a safety component of a product, covered by the EU harmonisation legislation listed in Annex I (Art. 6(1)): medical devices, machinery, toys, aviation. The latter go through the conformity assessment routes specific to their sectors, hence the longest transitional period. The postponement is not an amnesty: documentation, risk management and conformity assessment still take months.

The timeline in a nutshell

What to do now - the minimum plan

  1. Take an inventory of your AI systems - including those bought as SaaS and those employees use “on the quiet” (we write about Shadow AI separately).
  2. Classify the risk - prohibited / high / limited (transparency) / minimal. You can start with our AI Act Check quiz.
  3. Establish your role - provider, deployer, importer, distributor. The scope of your obligations depends on your role. Watch out: by modifying someone else's system or branding it as your own, you can get “promoted” to provider.
  4. Close the AI literacy gap - documented training and rules of use for staff working with AI. What "supporting competence" means after the Omnibus is covered in the article on Art. 4.
  5. For high-risk systems - start yesterday - documentation, risk management and conformity assessment are months of work, not weeks.
Law as of September 2026. The timeline is based on Art. 113 of Regulation 2024/1689 as amended by Regulation (EU) 2026/1744 (the Digital Omnibus on AI, in force since 27 July 2026). Keep an eye on communications from the Commission and the national supervisory authority - enforcement practice is only just taking shape.

This article is for information purposes only and does not constitute legal advice.

Frequently asked questions

When does the AI Act start to apply?

In stages: from 2 February 2025, prohibited practices (Art. 5) and AI literacy (Art. 4); from 2 August 2025, obligations for GPAI models plus supervision and penalties; from 2 August 2026, the transparency obligations under Art. 50 and most of the Regulation; and high-risk systems from 2 December 2027 (Annex III) and 2 August 2028 (Annex I).

What did the Digital Omnibus change in the AI Act timeline?

Regulation (EU) 2026/1744, in force since 27 July 2026, postponed the high-risk obligations under Annex III to 2 December 2027 and under Annex I to 2 August 2028. It also softened the wording of the AI literacy obligation in Art. 4 - from "ensuring" a sufficient level of literacy to "supporting the development" of that literacy - without repealing the obligation itself.

Does the Digital Omnibus's postponement also apply to the AI literacy obligation under Art. 4?

No. The AI literacy obligation under Art. 4 has applied since 2 February 2025 and was not postponed - the Digital Omnibus only changed the wording of the provision, not the date it applies from.

Is AI used in recruitment a high-risk system?

Yes - Annex III expressly lists AI in recruitment and workforce management as an example of a high-risk system. The obligations for that category apply from 2 December 2027, following the postponement introduced by the Digital Omnibus.

What penalties apply for breaching the AI Act?

Prohibited practices under Art. 5 carry fines of up to EUR 35 million or 7% of worldwide annual turnover. Most other infringements carry fines of up to EUR 15 million or 3% of turnover. The penalty provisions apply from 2 August 2025, but in Poland fines will be imposed by the Commission for the Development and Security of Artificial Intelligence (KRiBSI), whose inspection and sanctioning powers apply from 28 October 2026 (Art. 127 of the Polish Act on Artificial Intelligence Systems, Journal of Laws 2026, item 1003).

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