As illustrated by the timeline below, the obligations under the EU AI Act are being implemented in tranches. The initial obligations are now in force, with subsequent phases to follow, with guidelines and Codes of Practice also expected along the way. Notably, the Act does not require transposition into national law, so the requirements are applicable immediately on the effective dates.
In force
Not fully in force
August 2024
AI Act entered into force.
February 2025
Prohibitions on certain AI systems and AI literacy obligation commenced.
July 2025
Codes of Practice on general-purpose AI (GPAI) models published. Final guidance published to help providers and deployers of certain AI systems comply with the AI Act's transparency requirements from 2 August 2026.
August 2025
Rules for GPAI models entered into application.
August 2026
Most of the remainder of the AI Act applies but the main obligations for high-risk AI systems are delayed under the AI Omnibus to December 2027 and August 2028. The Commission’s enforcement powers in relation to general-purpose AI models enter into application.
December 2027
The requirements for stand-alone high-risk AI systems start to apply.
August 2028
Requirements for high-risk AI systems embedded in regulated products / safety components start to apply.
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© Eversheds Sutherland. All rights reserved. Eversheds Sutherland is a global provider of legal and other services operating through various separate and distinct legal entities. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.
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