Was the EU AI Act delayed? What actually has applied since 2 August 2026
Last updated 1 August 2026
“I heard the AI Act got postponed” is the single most dangerous sentence in AI compliance right now. Parts of the timeline really were moved — which is exactly why so many teams wrongly concluded the whole thing slipped. Here is what the law as in force actually says.
The staged timeline in Article 113
Regulation (EU) 2024/1689 entered into force on 1 August 2024 and applies in stages:
- 2 February 2025 — prohibitions (Article 5) and AI literacy obligations.
- 2 August 2025 — governance rules and obligations for general-purpose AI models.
- 2 August 2026 — the general application date, including the Article 50 transparency obligations for chatbots and synthetic content.
- 2 December 2027 and 2 August 2028 — the high-risk system obligations of Chapter III, Sections 1–3, as deferred by the 2026 Digital Omnibus (Annex III systems and Annex I embedded systems respectively).
What the “delay” actually is: the Digital Omnibus, now law
The European Commission's digital-omnibus simplification package became law as Regulation (EU) 2026/1744, published in the Official Journal on 24 July 2026. Two things matter for your planning:
- What moved: the high-risk obligations of Chapter III, Sections 1–3 — to 2 December 2027 (Annex III) and 2 August 2028 (Annex I embedded systems). See the full what-moved / what-didn't table.
- What did not move: the Article 50 transparency duties. The amending regulation left the 2 August 2026 general application date untouched — telling users they are talking to an AI is precisely the kind of low-burden rule simplification packages leave in place.
Treating the omnibus headlines as a blanket delay is a bet with asymmetric payoff: if you are wrong, you are non-compliant on day one of a regime with fines up to €15M or 3% of worldwide turnover for transparency breaches (Article 99(4)); if you are right, you spent a few hours adding disclosures users increasingly expect anyway.
What applies to a typical SaaS product on 2 August 2026
- Chatbot / voice-agent disclosure — Article 50(1). See is my chatbot covered?
- Machine-readable marking of AI-generated content — Article 50(2), if you provide generation features (see the C2PA guide).
- Deep-fake and public-interest text disclosure — Article 50(4), if you publish such content (see labelling AI-generated content).
- These apply to non-EU companies serving EU users too — details here.
What to do now
Article 50 compliance is unusual among EU tech regulation in being genuinely fast to implement: an inventory, a few disclosure strings, and marking for generated media. Work through the step-by-step checklist, or start with the free 3-minute check to see which paragraphs apply to your product at all. For the full obligation-by-obligation picture, see Article 50 is now in force: who must do what.
Not sure which obligations apply to you?
Run the free 3-minute Article 50 check