A complete overview of EU AI Act deadlines. Every deadline with its regulation reference, who it affects and what needs to be in place. Anti-fabrication: all dates verified against Regulation (EU) 2024/1689.
Regulation (EU) 2026/1744 (Digital Omnibus), which has entered into force, postpones the standalone Annex III high-risk deployer obligations to 2 December 2027. Article 50 (transparency) has not been postponed and has applied since 2 August 2026.
The EU AI Act enters into force
1 August 2024Reference: Regulation (EU) 2024/1689, Article 113
Affects: All AI providers, deployers, importers and distributors in the EU.
What now: The regulation is now law in every EU member state. The implementation period begins — most obligations apply in stages over 24-36 months.
Article 4 — AI literacy + Article 5 prohibited practices
2 February 2025Reference: Regulation (EU) 2024/1689, Article 4 + Article 5
Affects: All organisations that use AI systems (deployers + providers). Article 5 prohibits specific AI practices (manipulation, social scoring, real-time remote biometric identification in publicly accessible spaces, etc.).
What now: Article 4: 'take measures to support the development of AI literacy' (as amended by Regulation (EU) 2026/1744) among staff who operate or are affected by AI systems. PowerQuant Module 1 delivers an Article 4 register as documentation of compliance.
Article 50 — transparency disclosure
2 August 2026Reference: Regulation (EU) 2024/1689, Article 50
Affects: AI systems that interact with natural persons (chatbots, AI assistants). AI systems that generate synthetic audio, video, images or text (deepfakes, AI-generated content).
What now: Users must be informed that they are interacting with AI. AI-generated content must be marked as machine-generated. The PowerQuant Module 2 Procurement Evidence Pack includes an Article 50 disclosure checklist.
Annex III high-risk obligations (Article 6) — postponed to 2 December 2027 by Regulation (EU) 2026/1744
2 December 2027Reference: Regulation (EU) 2024/1689, Annex III; Regulation (EU) 2026/1744 (Digital Omnibus), in force
Affects: High-risk AI systems under Annex III: recruitment AI (point 4(a)), education AI (3), employee monitoring (4), credit scoring (5(b)), biometrics (1), critical infrastructure (2), law enforcement (6), migration (7), democratic processes (8(b)).
What now: Risk-management system (Art. 9), data governance (Art. 10), technical documentation (Art. 11), human oversight (Art. 14), accuracy/robustness/cybersecurity (Art. 15), post-market monitoring (Art. 72). PowerQuant Module 1 delivers a pre-conformity gap analysis; Module 3 (on request) covers full Annex IV technical documentation.
AI systems integrated into regulated products (Article 6(1))
2 August 2028Reference: Regulation (EU) 2024/1689, Article 6(1) + Annex I; originally Art. 113(c), postponed to 2 August 2028 by Regulation (EU) 2026/1744 (Digital Omnibus)
Affects: AI integrated as a safety component in products covered by EU harmonisation legislation (medical devices MDR/IVDR, machinery, toys, in-vitro diagnostics, etc.).
What now: Conformity assessment under the product-specific legislation plus an AI Act conformity layer. Notified-body involvement where relevant.
Frequently asked questions
When does the Annex III deadline apply after the Digital Omnibus?
2 December 2027 is the binding date for the standalone Annex III high-risk deployer obligations. Regulation (EU) 2026/1744 (Digital Omnibus), which has entered into force, postpones the deadline from the original application date in Art. 113. Article 50 (transparency) has not been postponed and has applied since 2 August 2026. HR-tech deployers should prepare now — buyer questionnaires are not going away.
Which deadline hits recruitment AI hardest?
Annex III point 4(a) (recruitment and selection) + the Article 6 high-risk obligations. The binding date is 2 December 2027 under Regulation (EU) 2026/1744 (Digital Omnibus), which has entered into force. Article 4 AI literacy has applied since 2 February 2025. Article 50 transparency disclosure (if the AI system communicates with candidates) has applied since 2 August 2026.
What are the Article 99 fines?
Up to €35M or 7% of worldwide annual turnover for prohibited AI practices (Article 5). Up to €15M or 3% for other infringements of the regulation. Up to €7.5M or 1% for supplying incorrect information to competent authorities. The penalty provisions already apply.
Are PowerQuant deliverables compliance certificates?
No. PowerQuant is a technical documentation provider — we deliver evidence packs as documentation. Conformity assessment of high-risk AI follows Article 43 and, where required, involves a notified body. We deliver the evidence that assessment needs.