EU AI Act deadlines and compliance calendar

Article 113 is the binding anchor for the AI Act calendar. Regulation (EU) 2026/1744 amended it after publication in the Official Journal on 24 July 2026. The amendment enters into force on 27 July 2026, keeps the 2 August 2026 general application date, and replaces the earlier high-risk schedule for Chapter III Sections 1-3.

Use one calendar row per application date. Each row should identify the legal provision, affected systems or models, accountable owner, required evidence, and the internal readiness date that comes before the legal application date.

The first operating deadline requires two active workstreams because Chapters I and II apply: an AI literacy owner for staff and other persons operating or using AI systems on the organisation's behalf, and a prohibited-practices owner for product and deployment screening.

The useful evidence is concrete: training audience, AI system context, role-specific literacy material, product-screening notes, and a release gate showing that prohibited-practice review happened before placing on the market, putting into service, or use.

The 2 August 2025 row should separate GPAI model-provider obligations from ordinary AI-system deployment work. Article 113 brings Chapter V into application on this date, while Commission GPAI guidance states that GPAI provider obligations enter into application on 2 August 2025.

For organisations building on third-party GPAI models, the calendar should still assign a procurement and product owner. They need model documentation requests, downstream integration records, supplier contact points, and evidence that the product team knows whether the organisation is only deploying a model, integrating it into an AI system, or significantly modifying it.

Use 2 August 2026 for the adopted Regulation's general application date, Article 50 transparency readiness, the start of Commission enforcement powers for GPAI provider obligations, and the Article 57 regulatory-sandbox deadline. These are different workstreams even though they share a date. The Commission published final Article 50 transparency guidelines on 20 July 2026; teams should use the final guidance for their last implementation review while treating the legal text as controlling.

Regulation (EU) 2026/1744 now makes 2 December 2027 the Chapter III Sections 1-3 application date for Annex III high-risk systems and 2 August 2028 the corresponding date for Article 6(1) systems. The separate 2 August 2027 transition applies to GPAI models placed on the market before 2 August 2025.

Article 111 creates specific transitional treatment for large-scale IT systems, pre-2 August 2026 high-risk systems, public-authority high-risk systems, and GPAI models placed on the market before 2 August 2025. It does not grant a general grace period to every AI system.

Keep these rows separate from Article 113. The owner must determine both when a chapter applies and whether an already-placed system or model is covered by a transition, has changed, is intended for public-authority use, or has a later compliance deadline.

Tie each calendar row to a system or model inventory view so product and compliance teams can see which obligations are approaching, which evidence is missing, and who can unblock the work.

Do not validate unsupported future guidance dates in the calendar. If a date is not in the cited source material, leave it out and track the dependency as a watch item rather than a legal milestone. Commission evaluation and reporting dates under Article 112 are also watch items, not direct operator compliance deadlines.

Set an internal readiness date for each binding milestone. The internal date should allow time for role and classification review, implementation, evidence approval, supplier follow-up, and release gating; it is an organisation's planning control, not a legal extension or a substitute for the application date.