EU AI Act in 2026: deadlines and obligations to check

For an AI project, a general timetable is only a starting point. Obligations also depend on the system's purpose and whether your business acts as a provider, deployer or another operator.

The July 2026 amendment changes several dates. Use the updated text and avoid assuming either that everything began in August or that everything was postponed.

Main dates after the amendment

Regulation (EU) 2026/1744 amends Article 113. For Chapter III, Sections 1, 2 and 3, subject to the exception stated in the text, the application dates are:

The Act's general application date remains 2 August 2026. Chapters I and II already applied from February 2025, subject to exceptions introduced for new prohibitions in the amendment.

Check the relevant provisions before turning this table into a product compliance schedule.

A creative studio is not automatically outside scope

Being a 3D studio, agency or small company does not by itself determine a system's classification. Intended purpose and context matter.

A visualisation project needs a different assessment from a tool used to select job candidates or support decisions in a regulated field. If the intended use changes, revisit the classification before reusing an earlier conclusion.

Record who develops, supplies and uses the system. Commercial product names alone do not establish those responsibilities.

Transparency and generated content

Article 50 distinguishes obligations including technical marking of certain outputs by providers and disclosure of certain content by deployers.

Not every use of AI is treated identically. Deepfakes and text intended to inform the public on matters of public interest have specific provisions, conditions and exceptions.

The amendment gives providers of synthetic-content systems placed on the market before 2 August 2026 until 2 December 2026 to comply with Article 50(2). Do not extend that transition automatically to all transparency obligations.

Our guide to content marking under Article 50 explores the distinction.

Prepare a project record

A short record makes the assessment practical:

• Describe what the system does and who receives its results.
• Identify the provider, professional user and publication responsibility.
• Record tools, versions and terms.
• Identify generated or modified content and its review process.
• Assign checks for marking, disclosure and record retention.
• Date each conclusion and link its legal source.

This does not replace legal analysis. It helps prevent a mixed set of obligations being reduced to “the deadline was postponed”.

Check the Spanish framework separately

The direct application of an EU regulation and the passage of Spanish legislation are separate matters. A bill must not be presented as an enacted law.

See the article on Spain's AI legislation and check the official parliamentary record before making a decision.

When planning a production, tell us what will be generated and where it will appear to organise technical and delivery requirements.