EU AI Act: what has applied since 2 August 2026

In May and June 2026 the EU institutions agreed the Digital Omnibus on AI, enacted as Regulation (EU) 2026/1744, which pushed the largest wave of obligations - those for high-risk AI systems - to 2 December 2027 and 2 August 2028.

2 August 2026 was not a non-event. The transparency layer took effect on that date and has applied ever since.

In force since 2 August 2026

• Chatbot disclosure (Art. 50(1)) - people must be told when they are interacting with an AI system.
• AI-generated content labelling (Art. 50(4)) - deepfakes and synthetic media must be marked.
• Emotion recognition and biometric categorisation notices (Art. 50(3)) - affected persons must be informed.
• Watermarking of AI-generated output (Art. 50(2)) - machine-readable markers on generated content.
• Prohibitions (Art. 5) and GPAI obligations (Art. 51-56), both already in force before that date.
• Article 4 - organisations should support their staff to building up adequate AI competency.

The next date: 2 December 2026

The four-month grace period for pre-existing generative systems ends on 2 December 2026. Output produced by systems that were already on the market before 2 August 2026 must carry machine-readable marking from that date. If you shipped a generative feature before last August and have not implemented marking yet, this is your live deadline.

What was deferred

Date	Provision
2 Aug 2027	Member states must have AI regulatory sandboxes established
2 Dec 2027	Annex III high-risk AI (HR, credit, education, law enforcement, biometrics, essential services)
2 Aug 2028	Annex I high-risk AI embedded in regulated products (medical devices, machinery, vehicles)

What to do now

1. Inventory every AI system in use. You need this whether or not you are high-risk.
2. Confirm your Article 50 disclosures are live, not planned - this is enforceable today.
3. Close the marking gap on pre-existing generative systems before 2 December 2026.
4. Start high-risk documentation - Annex IV documentation, human oversight and post-market monitoring take 12 to 18 months to build properly, and 2 December 2027 is closer than it reads.
5. Support your teams' AI competency - the cheapest obligation to meet and the one with the clearest return.

Take our free readiness assessment to see exactly which AI Act obligations apply to your systems today.