The EU AI Act — Regulation (EU) 2024/1689 — is not one deadline. It is a series of switches flipping at different dates for different populations. Most compliance failures will come from watching the wrong switch.

Already in force

Prohibited practices (Article 5) have been banned since 2 February 2025: manipulative techniques, social scoring, most real-time remote biometric identification in public, and several workplace and education uses of emotion recognition. If any current system touches these categories, the obligation was yesterday.

GPAI model obligations (Articles 53–55) have applied since 2 August 2025. Providers of general-purpose AI models owe documentation, a copyright policy, and a training-data summary; models with systemic risk carry added evaluation and incident-reporting duties.

2 August 2026 — the near switch

Article 50 transparency duties start applying: people interacting with a chatbot must be told it is a machine (unless obvious), and AI-generated content must be labeled as such in machine-readable form. This binds both providers and deployers — a company that merely operates a customer-service chatbot is in scope.

Article 101 enforcement powers become exercisable the same day: the Commission can demand documentation, evaluate models, order corrective measures, and fine GPAI providers up to 3% of global annual turnover or EUR 15 million, whichever is higher.

December 2027 — the heavy switch

High-risk system obligations (Annex III uses: employment, credit, insurance, education, essential services) — risk management, data governance, registration, human oversight — apply from December 2027 under the amended timeline. That date has moved once already; treat it as the deadline that matters for product planning, and track it.

What an operator does now

One inventory (every AI system you run, bought or built), one classification per system (prohibited / transparency-class / high-risk / minimal), one owner per obligation. The inventory is the step most deployers stall on — nothing downstream can start without it.

Independent regulatory intelligence — not legal advice. Matters with material exposure warrant counsel. Dates tracked on The Clock Board.