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
New Article 5(1)(ba)/(bb) prohibitions apply. The Article 111(4) transition for Article 50(2) marking of older synthetic-content systems ends.
Revised Product Liability Directive — national transposition deadline
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.
Annex III high-risk obligations (standalone systems)
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.
Annex I high-risk obligations (product-embedded AI)
High-risk regime for AI embedded as safety components in regulated products (machinery, medical devices, vehicles, lifts and other Annex I categories).
Already in force
Article 5 prohibitions + AI literacy (Article 4)
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.
General-purpose AI model obligations + governance structures
Obligations for general-purpose AI model providers (transparency, copyright policy, training-data summaries) and the EU governance layer (AI Office, AI Board) apply.
Irish AI Office — national coordination
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.
Article 50 transparency duties
Applicable chatbot, biometric and synthetic-content disclosure duties apply, including alongside high-risk classification. Provider marking and deployer disclosure are distinct.
What applies to you — now
| Your situation | Obligations today | Next key date |
|---|---|---|
| Any EU deployer or provider | Existing 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 products | Check 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 specifically | The 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.