Deadlines and transitional rules
When which duty applies, what is already in force, and what a realistic plan for your own organisation looks like.
The staging
| From | What applies |
|---|---|
| 2 February 2025 | Prohibited practices, the AI literacy duty |
| 2 August 2025 | Duties for general-purpose models, governance structure, GPAI penalties |
| 2 August 2026 | The main body: Annex III high-risk systems, transparency duties, national supervision and penalties |
| 2 August 2027 | High risk as an Annex I safety component, legacy GPAI models |
| Later | Legacy rules for public sector systems |
A realistic plan
- 01
Now: inventory and prohibitions
Capture every system and check it against the prohibition list. A prohibited use is unlawful today, not from 2026.
- 02
Now: AI literacy
Demonstrable competence of the people deploying, tied to the systems actually in use.
- 03
By mid-2026: classification and deployer duties
Class per system with reasoning, oversight designated, logging in place, those affected informed.
- 04
Ongoing: approval process
So new systems do not bypass the inventory and the classification stays current.
Transitional rules in detail
| Case | Rule |
|---|---|
| High-risk system placed on the market before the date | Transitional rule, lapses on substantial change of design |
| Public sector systems | Longer period, with a date for adaptation |
| GPAI models before August 2025 | Adaptation by August 2027 |
| Substantial modification | Ends grandfathering and triggers the full set of duties |
The last point is practically the most important. What counts as a substantial modification is measured against the intended purpose and the behaviour. A change of the underlying model, a change of input data, or an extension of the field of use can fall under it, even where the interface stays the same.
Penalties
| Breach | Range |
|---|---|
| Prohibited practices | up to 35 m EUR or 7 % of worldwide annual turnover |
| Other breaches of duty | up to 15 m EUR or 3 % |
| Incorrect or incomplete information | up to 7.5 m EUR or 1 % |
For small and medium enterprises the lower of the two figures applies. Member states set the procedures; market surveillance is national, with the Commission's AI Office for GPAI models.
What to document now
- Date of first inventory entry per system.
- Date and result of the prohibition check.
- Evidence of AI literacy with dates and reference to the specific system.
- For legacy systems: the state at the cut-off date, so a later substantial modification stays recognisable.
The last point is rarely done and later decides whether grandfathering can be evidenced at all.
Related courses and sources
AI Act Explorer
A searchable, cross-linked edition of the EU AI Act. Jumps from an article straight to its recitals.
Far more pleasant than the PDF, but not the official version. When in doubt, use the full text.
The Commission's regulatory framework
The official overview of the AI Act with timeline, guidelines and pointers to implementing acts. The starting point for any question about deadlines.
The starting point for any deadline question, because the official timeline sits here.