Articles Posted in The EU AI Act (AI Act)

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The European Union’s AI Act entered a new phase on August 2, 2026, marking two years since its entry into force. Most immediately, the transparency obligations in Article 50 now apply to a broad range of AI systems and their providers and deployers, and the AI Act’s enforcement machinery is operational for obligations that are already in force.

August 2, 2026, was also the date on which the core requirements for “high-risk” AI systems were due to become applicable. That did not happen, however. Following political agreement reached by the EU institutions and the later publication of the Digital Omnibus Regulation on AI (“AI Omnibus Regulation”), those requirements have been postponed until December 2, 2027, for Annex III standalone use cases and August 2, 2028, for most product-related systems.

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The European Commission has published its regulatory proposal for the EU Digital Omnibus, a package of amendments seeking to streamline EU rules on data protection, artificial intelligence and digital regulation in an effort to improve EU competitiveness. For more information on the background to the Digital Omnibus, see our earlier briefing here. The Digital Omnibus is split into two regulations, one targeting the AI Act and another targeting other EU digital regulations.

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The EU AI Act (AI Act), effective since February 2025, introduces a risk-based regulatory framework for AI systems and a parallel regime for general-purpose AI (GPAI) models. It imposes obligations on various actors, including providers, deployers, importers and manufacturers, and requires that organizations ensure an appropriate level of AI literacy among staff. The AI Act also prohibits “unacceptable risk” AI use cases and imposes rigorous requirements on “high-risk” systems. For a comprehensive overview of the AI Act, see our earlier client alert.

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