LiveVerified 2026-10-08 · Single source of truth

EU AI Act — Live Law Radar

Key implementation milestones, reviewed against the enacted Digital Omnibus Regulation (EU) 2026/1744. Most published guides and compliance tools still show the original August 2026 high-risk date — that date no longer applies.

Digital Omnibus: In force from 27 July 2026

Enacted high-risk deferrals

  • • Annex III high-risk: Aug 2026 → Dec 2, 2027 (+16 months)
  • • Annex I product-embedded: Aug 2027 → Aug 2, 2028 (+12 months)

NOT deferred — still in force or on track

  • • Article 5 prohibitions (in force since Feb 2025)
  • • GPAI obligations (in force since Aug 2025)
  • • Article 50 transparency (Aug 2, 2026; limited legacy marking transition)
  • • Product Liability Directive (Dec 9, 2026)

Source: Regulation (EU) 2026/1744. New Article 5 prohibitions and the legacy marking transition have a separate 2 December 2026 date.

Upcoming

New intimate-material and CSAM prohibitions; legacy marking transition ends

2 December 2026
48d

New Article 5(1)(ba)/(bb) prohibitions apply. The Article 111(4) transition for Article 50(2) marking of older synthetic-content systems ends.

Who:Operators in the specified use cases; providers of legacy synthetic-content systems
Other applicable criminal, privacy and image-abuse laws may already prohibit the conduct.

Revised Product Liability Directive — national transposition deadline

9 December 2026
55d

The revised directive expressly covers software. Liability depends on the relevant economic operator, a defect, qualifying damage and causation, with statutory presumptions in specified circumstances.

Who:Relevant manufacturers and other economic operators; assess substantial modifications
Check national implementing law. Applies to products placed on the market or put into service after 9 December 2026. Compliance is not immunity from liability.

Annex III high-risk obligations (standalone systems)

2 August 20262 December 2027
413d — deferred

Full high-risk regime for Annex III use cases — employment screening, credit scoring, education access, critical infrastructure and more: risk management, human oversight, logging, deployer duties under Article 26.

Who:Providers and deployers of Annex III high-risk AI
Enacted by Regulation (EU) 2026/1744, in force 27 July 2026. Article 111 legacy-system transitions require a separate assessment.

Annex I high-risk obligations (product-embedded AI)

2 August 20272 August 2028
657d — deferred

High-risk regime for AI embedded as safety components in regulated products (machinery, medical devices, vehicles, lifts and other Annex I categories).

Who:Providers and deployers of product-embedded AI
Enacted by Regulation (EU) 2026/1744. Both Article 6(1) conditions must be met; Annex I Section B follows sectoral rules.

Already in force

Article 5 prohibitions + AI literacy (Article 4)

2 February 2025
In force

Existing prohibited practices apply. Article 4 requires providers and deployers to take measures supporting staff AI literacy, tailored to context; it does not require a guaranteed individual competency level.

Who:Every provider and deployer — already in force
NOT deferred by the Digital Omnibus.

General-purpose AI model obligations + governance structures

2 August 2025
In force

Obligations for general-purpose AI model providers (transparency, copyright policy, training-data summaries) and the EU governance layer (AI Office, AI Board) apply.

Who:GPAI model providers — already in force

Irish AI Office — national coordination

2 August 2026
In force

The AI Office of Ireland is operational as the national coordinating body and single point of contact. Its board appointments were announced on 5 August 2026.

Who:Irish organizations — your national regulator takes shape
Date shown is the announced establishment target, not an asserted commencement date. The Article 70 national designation deadline was 2 August 2025.

Article 50 transparency duties

2 August 2026
In force

Applicable chatbot, biometric and synthetic-content disclosure duties apply, including alongside high-risk classification. Provider marking and deployer disclosure are distinct.

Who:Providers and deployers within the relevant Article 50 use cases
Article 111(4) gives pre-2 August 2026 synthetic-content systems a limited marking transition only.

What applies to you — now

Your situationObligations todayNext key date
Any EU deployer or providerExisting Article 5 bans, revised AI literacy measures and applicable Article 50 transparency duties apply. GPAI model duties depend on your role as model provider.Dec 2, 2026 — additional prohibitions and legacy provider marking deadline
Deployer of Annex III AI (HR, credit, education, etc.)Existing bans, literacy, applicable transparency duties and GDPR continue to apply. Annex III high-risk duties generally apply from Dec 2, 2027, subject to transitional provisions.Dec 2, 2027 — Annex III obligations apply
Relevant economic operators supplying AI productsCheck national implementation and operator role. The revised PLD covers products marketed or put into service after Dec 9, 2026. Defect, qualifying damage and causation matter; documentation is not immunity.Dec 9, 2026 — PLD transposition deadline
Irish business specificallyThe Irish AI Office is operational as national coordinator. Consult its authority directory for your sector. The European AI Office oversees GPAI models.Consult the current competent-authority directory

Maintained by Aeqora · Verified 2026-10-08 against cited primary sources · Methodology · Vendor Risk Index · Trust Center

This tracker reflects enacted Regulation (EU) 2026/1744. Applicability depends on use case, operator role and transitional provisions. This is informational, not legal advice.