The AI Act’s next big deadline is here

On 2 August 2026, the EU AI Act reaches its general date of application — the point at which most of its provisions take effect and enforcement begins in earnest, at both national and EU level, for the rules already in force.

For many organisations, the most immediate change will be the arrival of the Article 50 transparency obligations. These require businesses to tell people when they are interacting with certain AI systems; to mark AI-generated or manipulated content in a machine-readable format (subject to an extended transitional deadline of 2 December 2026 for AI systems already on the market as at 2 August 2026); and, in specified circumstances, to disclose the use of deepfakes, emotion-recognition and biometric-categorisation systems, and AI-generated text on matters of public interest.

The date matters just as much for providers of general-purpose AI models. The GPAI obligations have applied since August 2025, but from 2 August 2026 the Commission can bring its full supervisory and enforcement powers to bear — requiring information or model evaluations, directing providers to take mitigation measures, and imposing fines.

However, 2 August 2026 is no longer the main compliance date for high-risk AI systems. Following the Digital Omnibus on AI, the principal remaining milestones are:

• 2 December 2026: the new prohibitions concerning non-consensual intimate material and child sexual abuse material apply. This is also the transitional deadline for certain generative AI systems placed on the market before 2 August 2026 to comply with the Article 50(2) content-marking obligation.
• 2 August 2027: Member States should have at least one national AI regulatory sandbox operational.
• 2 December 2027: the requirements for stand-alone high-risk AI systems falling within the use cases listed in Annex III apply.
• 2 August 2028: the requirements for high-risk AI systems embedded in, or themselves constituting, regulated products covered by Annex I apply.

In short, 2 August 2026 is a substantial compliance milestone — but not the finishing line. The AI Act remains a rolling implementation programme, with further obligations, guidance, codes of practice and technical standards still to come.

Bristows has followed the Act from the Commission’s original 2021 proposal through to the final Regulation, the GPAI Code of Practice and the recent Digital Omnibus reforms. Subscribe to receive our future insights direct to your inbox.

Below, we have collected our principal AI Act articles from our AI website, covering the Act’s development and practical implications across a range of legal and sectoral issues.