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AIGO — EU AI Act Applicability and Timeline

1. Document Purpose

This document defines the controlled applicability and timeline model for the AIGO mapping of Regulation (EU) 2024/1689, the EU Artificial Intelligence Act, as amended by Regulation (EU) 2026/1744. Its purpose is to establish a single authoritative timeline for:
  • entry into force;
  • phased application;
  • prohibited AI practices;
  • AI literacy;
  • governance;
  • general-purpose AI;
  • transparency;
  • high-risk AI;
  • conformity assessment;
  • registration;
  • enforcement;
  • transitional provisions;
  • significant-change rules;
  • public-authority transition requirements; and
  • future regulatory review.
This document is the authoritative timeline source for the other EU AI Act mapping files in: mappings/eu-ai-act/ Those files should reference this document instead of independently maintaining competing application dates. This document is an operational regulatory mapping and does not constitute legal advice or a legal determination of applicability for a specific organization.

2. Mapping Information

Regulation (EU) 2026/1744 was signed on 8 July 2026, published in the Official Journal on 24 July 2026, and entered into force on 27 July 2026. It amended the AI Act’s application timetable and transitional arrangements.

3. Authoritative Timeline Principle

The AIGO EU AI Act mapping package shall maintain one controlled timeline source. The authoritative sequence is:
The organization must distinguish:
  • legal entry into force;
  • entry into application;
  • enforcement availability;
  • transitional deadlines;
  • future compliance deadlines;
  • voluntary early-readiness dates.
These concepts are not interchangeable.

4. Entry Into Force of the AI Act

Regulation (EU) 2024/1689 entered into force on: 1 August 2024. The original AI Act established a staggered implementation model rather than making all provisions applicable immediately. Regulation (EU) 2026/1744 subsequently revised parts of that timetable. AIGO should therefore maintain:
separately from the application dates below.

5. Digital Omnibus Entry Into Force

Regulation (EU) 2026/1744 entered into force on: 27 July 2026. This date is legally significant because several provisions of the amended AI Act began applying on that date, including Articles 102–110 as specified by the amended Article 113. AIGO should maintain:

6. Master Timeline

The current AIGO baseline is: The 2026 amendment explicitly establishes the revised 2026, 2027, and 2028 dates and the 2030 public-authority deadline.

7. 1 August 2024 — Entry Into Force

The AI Act entered into force on: 1 August 2024. Entry into force means the Regulation became part of the EU legal order; it does not mean that every substantive obligation became applicable on that date. AIGO should therefore never describe 1 August 2024 as the universal compliance deadline.

8. 2 February 2025 — Chapters I and II

Under the amended Article 113, Chapters I and II apply from: 2 February 2025 except for the newly introduced or amended Article 5 provisions specified separately for application from 2 December 2026. The Commission summarizes the earlier application date as covering:
  • definitions;
  • prohibited AI practices under the initial prohibition set;
  • AI literacy;
  • other provisions within the applicable Chapters I and II.

9. AI Literacy — 2 February 2025

AI literacy obligations began applying on: 2 February 2025. The amended Article 4 retains the requirement for providers and deployers to take measures to support AI literacy while clarifying that they are not required to guarantee a specific level of AI literacy for an individual. AIGO status:
Detailed mapping: 06-AIGO-EU-AI-Act-AI-Literacy-Mapping-v0.1.md

10. Original Article 5 Prohibitions — 2 February 2025

The original Article 5 prohibition framework became applicable from: 2 February 2025 subject to the specific later application date for the provisions added or revised by the 2026 amendment. AIGO should therefore not use one single “Article 5 effective date” field. Instead:
should be stored.

11. New Article 5 Provisions — 2 December 2026

The 2026 amendment provides that specified new or amended Article 5 provisions apply from: 2 December 2026. AIGO should classify these as:
until that date. The Article 5 mapping must identify the specific provision rather than treating all prohibited practices as sharing an identical application date.

12. 2 August 2025 — Governance Rules

The Commission identifies: 2 August 2025 as the application date for the governance rules. This includes the AI governance architecture established by the AI Act. AIGO governance mappings should therefore treat the relevant governance requirements as:

13. 2 August 2025 — GPAI Obligations

The GPAI obligations became applicable on: 2 August 2025. The Commission confirms this date in its current GPAI implementation guidance. AIGO status:
Detailed mapping: 05-AIGO-EU-AI-Act-GPAI-Mapping-v0.1.md

14. 2 August 2026 — General Application Date

The general application date is: 2 August 2026. The Commission continues to describe 2 August 2026 as the AI Act’s general application date, subject to the specific exceptions and later dates established by the amended Article 113. As of this mapping version’s baseline date: 14 August 2026 the general application date has already passed. AIGO should therefore treat the applicable provisions that have reached their legal application dates as operational rather than future readiness items.

15. Article 50 Transparency — 2 August 2026

Article 50 transparency obligations form part of the current AI Act implementation framework. The European Commission’s final transparency guidance confirms that Article 50 transparency obligations apply from: 2 August 2026. This includes the applicable obligations concerning:
  • direct interaction;
  • synthetic content;
  • deepfakes;
  • public-interest AI-generated text;
  • emotion recognition;
  • biometric categorisation.
Detailed mapping: 04-AIGO-EU-AI-Act-Transparency-Mapping-v0.1.md

16. 2 December 2026 — Pre-Existing Synthetic Content

Article 111(4), as added by Regulation (EU) 2026/1744, provides a specific transition for providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video, or text content that were placed on the market before: 2 August 2026. Those providers must take the necessary steps to comply with Article 50(2) by: 2 December 2026. AIGO should represent this as:
rather than:

17. 2 December 2027 — Annex III High-Risk AI

The revised Article 113 establishes: 2 December 2027 as the application date for Chapter III, Sections 1–3, for AI systems classified as high-risk under:
  • Article 6(2); and
  • Annex III.
This includes the main requirements concerning:
  • risk management;
  • data and data governance;
  • technical documentation;
  • record keeping;
  • transparency;
  • human oversight;
  • accuracy;
  • robustness;
  • cybersecurity;
  • provider/deployer obligations;
  • conformity-related governance.
The legal text expressly sets this date.

18. 2 August 2028 — Annex I High-Risk AI

The revised Article 113 establishes: 2 August 2028 as the application date for Chapter III, Sections 1–3, for AI systems classified as high-risk under:
  • Article 6(1); and
  • Annex I.
This creates a separate timetable for high-risk AI embedded in regulated products. The Commission’s current implementation material confirms the same distinction.

19. High-Risk Timeline Architecture

AIGO must maintain two separate high-risk application fields:
This must not be collapsed into one generic “high-risk effective date.”

20. Public-Authority High-Risk Systems — 2 August 2030

Article 111(2), as amended by Regulation (EU) 2026/1744, provides that providers and deployers of high-risk AI systems intended to be used by public authorities must take the necessary steps to comply with the Regulation by: 2 August 2030. This is an additional transitional rule. AIGO should represent it as:
It should not override the ordinary application-date fields for other systems.

21. High-Risk Systems Placed on the Market Before Chapter III Application

Article 111(2), as amended, states that for other high-risk AI systems placed on the market or put into service before the relevant Chapter III application date, the Regulation applies only if those systems undergo significant changes in design from that date, subject to the separate public-authority rule. AIGO should therefore record:

22. Significant-Change Trigger

For transitional high-risk systems, a significant design change may cause the relevant high-risk obligations to apply. AIGO should therefore include a: High-Risk Significant-Change Assessment with:
  • original system version;
  • original market date;
  • change date;
  • change description;
  • design impact;
  • legal assessment;
  • conformity impact;
  • documentation impact;
  • decision.

23. Significant Change and AIGO Change Management

The relationship should be:
This assessment should be integrated with: 11-AIGO-AI-Change-Management-Template-v0.1.md and the corresponding Change Schema.

24. 27 July 2026 — Articles 102–110

Regulation (EU) 2026/1744 adds a specific Article 113 date stating that Articles 102–110 apply from: 27 July 2026. These provisions should therefore be treated as currently applicable from the Digital Omnibus entry-into-force date. AIGO should not use 2 August 2026 as a universal date for all amended provisions.

25. Timeline Categories

AIGO should use controlled applicability values:
These values allow legal status and operational readiness to be represented separately.

26. Entry Into Force Versus Application

AIGO shall distinguish:

Entry Into Force

The legislation becomes legally operative as a Union legal instrument.

Entry Into Application

A specific provision begins imposing or activating its substantive requirements.

Enforcement Availability

A competent authority obtains the applicable power or responsibility to supervise/enforce.

Transitional Deadline

An additional date by which a covered existing system must complete compliance steps. These are separate data concepts.

27. Regulatory Timeline Record

Each timeline record should include:

28. Recommended Timeline IDs

The current package should use stable identifiers such as:
The exact number should be maintained in the mapping registry.

29. Core Timeline Records

Recommended initial records:

30. Application Status as of 14 August 2026

At this document’s baseline date:

Currently Applicable

  • AI Act is in force;
  • Chapters I and II applicable, subject to specified exceptions;
  • AI literacy;
  • original applicable prohibitions;
  • governance;
  • GPAI obligations;
  • general AI Act provisions reaching their application dates;
  • Article 50 transparency obligations;
  • Articles 102–110 under the amended schedule.

Future

  • new Article 5 provisions: 2 December 2026;
  • pre-existing synthetic-content Article 50(2) transition deadline: 2 December 2026;
  • Annex III high-risk Chapter III Sections 1–3: 2 December 2027;
  • Annex I high-risk Chapter III Sections 1–3: 2 August 2028;
  • public-authority high-risk transition: 2 August 2030.
This classification is based on the current amended Article 113 and Article 111.

31. AIGO Current-State Rule

At any point in time, the applicability engine should calculate:
from:
  • event date;
  • current date;
  • actor;
  • AI category;
  • transition;
  • legal condition.
It should not simply compare the current date with one global AI Act deadline.

32. Applicability Decision Algorithm

A conceptual decision sequence is:

33. Applicability Status Examples

Example A — Article 4 AI Literacy

Example B — Annex III High-Risk Obligation

Example C — Annex I High-Risk Obligation


34. Early-Readiness Status

AIGO should separately support:
This allows organizations to prepare before the statutory date without incorrectly claiming that the requirement is currently legally applicable.

35. Early Implementation Rule

Where an organization voluntarily implements a future requirement early, the evidence should identify:
  • legal application date;
  • organizational implementation date;
  • reason for early implementation;
  • implemented scope;
  • whether the organization intends to maintain the control until legal application.

36. Mapping Document Rule

All EU AI Act mapping documents should refer to this timeline document for dates. For example:
A detailed document may mention a date for readability, but the authoritative date should remain centralized here.

37. No Duplicate Timeline Authority

The following files should not independently become competing timeline sources:
  • main mapping;
  • prohibited practices mapping;
  • high-risk mapping;
  • transparency mapping;
  • GPAI mapping;
  • AI-literacy mapping;
  • governance mapping;
  • conformity mapping;
  • rights mapping;
  • Annex mapping.
Those documents may describe relevant dates but should reference this document as authoritative.

38. Timeline Change Control

Any change to an application date should require:
  1. legal source verification;
  2. impact analysis;
  3. timeline update;
  4. affected mapping identification;
  5. consistency validation;
  6. evidence update;
  7. review;
  8. approval.

39. Regulatory Change Example

If the EU changes the Annex III application date:

40. Timeline and Control Activation

AIGO controls may be:
This is an AIGO operational status and should not be confused with the legal status.

41. Timeline and Assessment Activation

Assessments should use the legal timeline to determine whether they are:
  • required now;
  • required in transition;
  • required before a planned deployment;
  • future readiness;
  • not applicable.

42. Timeline and Approval

An approval workflow should verify:
  • current legal status;
  • future obligations;
  • transition;
  • planned implementation date;
  • relevant controls.
A future legal requirement may become an approval condition before its legal application date as an organizational risk decision.

43. Timeline and Monitoring

Monitoring should track approaching deadlines. Recommended indicators:
These are management indicators, not statutory compliance metrics.

44. Timeline and Incident Management

A missed application deadline or transition deadline may become a regulatory incident. AIGO should record:
  • provision;
  • deadline;
  • affected system;
  • missed action;
  • cause;
  • containment;
  • remediation;
  • authority notification if applicable.

45. Timeline and Change Management

The Change Management process should evaluate whether legal timing creates:
  • immediate implementation;
  • future implementation;
  • transition;
  • grandfathering;
  • significant-change trigger.

46. Timeline and Management Review

Management review should include upcoming material dates. Recommended horizon:
  • 90 days;
  • 180 days;
  • 12 months;
  • next major regulatory milestone.
The organization may use different horizons according to risk.

47. Timeline and Assurance

Assurance should periodically verify that:
  • legal dates are current;
  • controls activated on time;
  • transition provisions are correctly applied;
  • early-readiness claims are labelled;
  • significant-change triggers are assessed.

48. Timeline Evidence

Evidence should include:
  • legal source;
  • amendment;
  • applicability assessment;
  • system classification;
  • transition assessment;
  • control activation;
  • readiness decision;
  • review.

49. Transition Evidence

For systems benefiting from a transition, AIGO should retain evidence of:
  • why transition applies;
  • relevant market date;
  • system version;
  • legal basis;
  • transition deadline;
  • actions taken;
  • final compliance date.

50. Grandfathering and Existing Systems

AIGO should avoid using the term “grandfathered” as a generic legal status. Instead, the system should record the precise transitional rule. For example:
The legal outcome depends on the exact provision.

51. Pre-Existing High-Risk Systems

For non-public-authority high-risk systems placed on the market or put into service before the relevant Chapter III application date, Article 111(2) provides a significant-change trigger for the later application of the Regulation. AIGO should therefore maintain historical market-placement information.

52. Public-Authority Systems

For high-risk AI systems intended to be used by public authorities, the amended Article 111(2) requires necessary compliance steps by: 2 August 2030. AIGO should maintain a distinct public-authority applicability flag.

53. Public-Authority Flag

Recommended controlled value:
Possible values:
This field should influence the applicability engine.

54. Timeline and Annex XIV

Annex XIV is part of the current amended legal architecture. Its notified-body designation scope should be evaluated according to the current legal regime, including the transitional arrangements concerning certain notified bodies. This is especially important for Article 6(1) systems subject to the later 2028 application date.

55. Timeline and GPAI

GPAI obligations became applicable on: 2 August 2025 and remain currently applicable. AIGO should distinguish:
from:
A downstream system may have a different regulatory timeline.

56. Timeline and Transparency

Article 50 is now in the general application period, but Article 111(4) creates a specific transition for certain pre-existing synthetic-content systems until: 2 December 2026. AIGO should therefore calculate Article 50 applicability at system level rather than using a simple organization-wide date.

57. Timeline and Prohibited AI

The 2026 amendment introduced later application dates for specified Article 5 provisions. AIGO should therefore map each prohibited-practice record to:
  • article;
  • paragraph;
  • point;
  • effective date;
  • transitional status.

58. Timeline and AI Literacy

AI literacy remains a current obligation. The organization should not postpone Article 4 governance until the later high-risk dates.

59. Timeline and Governance

Governance obligations are already applicable. The AIGO Governance model should therefore be considered a current implementation area rather than a future-only framework.

60. Timeline and Enforcement

The amended AI Act also sets application dates for specific supervisory and enforcement provisions. Articles 102–110 apply from: 27 July 2026. AIGO should therefore update its governance/enforcement readiness baseline accordingly.

61. Timeline and Regulatory Authorities

Because supervisory competence can differ by AI system and actor, applicability records should include:
  • authority;
  • jurisdiction;
  • legal provision;
  • application date;
  • enforcement date where distinct.
The organization should not assume that every obligation is enforced by the same EU or national body.

62. Regulatory Date Source Control

Every timeline event should include a source reference. Recommended source types:
Secondary sources should not become the authoritative source.

63. Timeline Source Currency

The timeline should be revalidated:
  • after every amendment;
  • after new implementing legislation;
  • after delegated acts;
  • after official implementation changes;
  • before each AIGO mapping release.

64. Current Legal Sources

The baseline source set for this version is:

Regulation (EU) 2024/1689

The foundational AI Act.

Regulation (EU) 2026/1744

The current Digital Omnibus amendment.

European Commission AI Act Regulatory Framework

The Commission’s current implementation timeline and AI Act overview.

European Commission AI Act FAQ

Current implementation and application explanations.

65. Timeline Registry

The machine-readable mapping registry should eventually include:
The actual registry schema should remain aligned with: 00-AIGO-EU-AI-Act-Mapping-Registry-v0.1.json

66. Timeline Validation

The AIGO validation process should verify:

Date Accuracy

The date matches the current legal source.

Scope Accuracy

The date applies to the correct provision.

Actor Accuracy

Affected actors are identified.

System Accuracy

Affected AI categories are identified.

Transition Accuracy

Transitional rules are represented.

Change Accuracy

Significant-change rules are represented.

Status Accuracy

Current / future / transitional status is correct.

67. Timeline Findings

Potential findings include:

68. Critical Timeline Findings

Potential critical findings include:
  • incorrect statutory application date;
  • high-risk timeline incorrectly centralized to one date;
  • transition deadline omitted;
  • public-authority transition omitted;
  • new Article 5 effective date omitted;
  • enforcement application date misrepresented;
  • obsolete 2024 timeline used without 2026 amendment.

69. Timeline and AIGO Repository Health

Repository Health should flag:
  • conflicting dates;
  • stale mapping files;
  • missing timeline registry;
  • duplicate timeline authorities;
  • unsupported future dates;
  • historical dates presented as current.

70. Timeline and Framework Consistency

The Framework Consistency Checker should compare:
  • this timeline document;
  • main mapping;
  • high-risk mapping;
  • transparency mapping;
  • GPAI mapping;
  • governance mapping;
  • conformity mapping;
  • Annex mapping;
  • machine-readable registry.
A date conflict should produce a consistency finding.

71. Timeline and Document Integrity

The Document Integrity Checker should ensure:
  • timeline file exists;
  • document version is controlled;
  • dates are machine-readable where needed;
  • source links are valid;
  • registry entries resolve.

72. Timeline and Evidence

A timeline update should produce evidence such as:
  • legal source;
  • legal review;
  • affected artifacts;
  • change record;
  • approval;
  • updated version.
This enables an auditable regulatory-change trail.

73. Timeline and Regulatory Change Management

Recommended process:

74. Timeline and Continuous Improvement

Repeated timeline discrepancies should generate improvement actions. Potential improvements:
  • automated date checks;
  • centralized registry;
  • rule-version control;
  • source monitoring;
  • release gates;
  • timeline validation.

75. AIGO Operational Status Model

For every regulated AI requirement, AIGO should support:
The legal status and implementation status should be stored separately.

76. Example Combined Record

This demonstrates why a single status field is insufficient.

77. Timeline Review Board

Material timeline changes should be reviewed by:
  • Legal/Compliance;
  • AI Governance;
  • Framework Architecture;
  • affected Control Owners;
  • Evidence Owner;
  • Assurance.
The review should determine whether the change affects operational requirements.

78. Timeline Release Gate

Before release of any EU AI Act mapping package, verify:

79. Timeline Review Triggers

Immediate review is required after:
  • AI Act amendment;
  • Digital Omnibus amendment;
  • Article 5 change;
  • Article 50 change;
  • GPAI change;
  • high-risk application-date change;
  • new transitional rule;
  • public-authority rule change;
  • new supervisory provision.

80. Current Baseline Summary

As of 14 August 2026:
The dates above reflect the current amended Article 111 and Article 113 baseline.

81. Legal and Operational Disclaimer

The timeline is intended to support AIGO governance and planning. It should not be used as a substitute for determining the legal applicability of a particular AI system. Specific applicability may depend on:
  • actor;
  • system;
  • intended purpose;
  • jurisdiction;
  • market status;
  • product legislation;
  • exceptions;
  • significant changes;
  • transitional provisions;
  • sectoral law.

82. Relationship to Other EU AI Act Mappings

This document is the authoritative timeline source for all of them.

83. Relationship to AIGO Schemas


84. Relationship to AIGO Tools

The timeline should be validated by:
  • Schema Validator;
  • Reference Validator;
  • Traceability Validator;
  • Framework Consistency Checker;
  • Document Integrity Checker;
  • Repository Health Checker.
The Control Coverage and Evidence Coverage Validators should use timeline status when determining current versus future obligations.

85. Document Control


86. Document Status

Document: AIGO — EU AI Act Applicability and Timeline Version: 0.1 Status: Draft Working Name: AIGO Full Name: AI Governance Operating Framework Document Identifier: AIGO-MAP-EUAI-011 Document Type: EU AI Act Mapping This document defines the authoritative AIGO applicability and timeline model for the EU AI Act, including entry into force, phased application, Article 5, AI literacy, governance, GPAI, Article 50 transparency, high-risk AI, conformity-related timing, transitional rules, significant-change rules, public-authority deadlines, and the 2026 Digital Omnibus amendments. End of Document