The AI Act does not arrive all at once. Its obligations switch on in tranches, and
the Digital Omnibus moved the heaviest ones later. Here is when each part applies, taken from the
consolidated text — and where the standards have to be ready before the light turns green.
1 August 2024
Entry into force
The Regulation enters into force, twenty days after publication in the Official Journal. The clock on every date below starts here.
Article 113
2 February 2025
Prohibitions and AI literacy
Chapters I and II apply: the Article 5 prohibited practices, and the Article 4 duty to ensure a sufficient level of AI literacy. A first set of obligations with real teeth, and no standards behind them.
Article 113(a)
2 August 2025
GPAI, governance and penalties
Obligations for general-purpose AI models (Chapter V), the governance architecture and the AI Office and Board (Chapter VII), the penalty regime (Chapter XII, bar one article), the notifying authorities, and the confidentiality rule of Article 78.
Article 113(b)
2 August 2026
General application
The Regulation applies as a whole. The high-risk obligations sit behind this date, staged into the two deadlines below — which is where most of the work, and this Observatory's subject, now lives.
Article 113
2 December 2026
The added prohibitions
The prohibitions inserted into Article 5 by the Digital Omnibus switch on, a little after the general application date.
Article 113(a) · as amended
2 December 2027
High-risk: Annex III
The core obligations for high-risk systems classified under Article 6(2) and Annex III apply. This is the deadline most high-risk providers are working to, and the one the harmonised standards are racing. If a standard is to carry a presumption of conformity here, it has to be published and cited in the Official Journal before this date.
Article 113(c)(i) · as amended
2 August 2028
High-risk: Annex I
The obligations for high-risk systems that are safety components of products already regulated under Article 6(1) and Annex I apply — the later of the two high-risk deadlines, giving that route eight more months.
Article 113(c)(ii) · as amended
Why this is the runway
The standards have to land first.
Following a harmonised standard is the practical way to a presumption of conformity, but a standard
only counts once it is published and cited in the Official Journal — and citation is at the Commission's
discretion, after publication. For Annex III high-risk, that has to happen before December 2027. The
M/613 standards are in drafting now. The distance between "in enquiry" and "cited in the OJEU," against
that date, is the gap this Observatory watches.
Dates taken from the consolidated Regulation (EU) 2024/1689, version 02024R1689 of
27 July 2026 (Article 113, as amended). Application dates and their scope can change; always confirm
against the Official Journal before relying on them.
