EU AI Act deadlines for startups
The AI Act entered into force on 1 August 2024. The AI Omnibus, in force from 27 July 2026, changed several dates (Article 113).
- 2 Feb 2025: Article 5 prohibited practices and the Article 4 AI literacy provisions apply.
- 2 Aug 2025: General-purpose AI model obligations (Art. 53–55), governance, and penalties apply.
- 2 Aug 2026: General application, including Article 50 transparency obligations. Enforcement of prohibitions, transparency and GPAI rules starts.
- 2 Dec 2026: New ban on AI generating non-consensual intimate imagery and CSAM. Art. 50(2) marking deadline for generative systems placed on the market before 2 Aug 2026.
- 2 Dec 2027: High-risk obligations for Annex III systems (employment, credit, education, biometrics and so on). National sandboxes are due.
- 2 Aug 2028: High-risk obligations for AI in Annex I regulated products.
What a startup should do now
- Inventory every AI feature you build or use.
- Classify each one (prohibited / high / limited / minimal).
- Ship Article 50 notices now. They already apply.
- If you're high-risk, start your technical documentation and quality management system now. 2027 is closer than it looks.
Not legal advice. Last reviewed 26 Oct 2026.