EU AI ActRoadmap

EU AI Act (Regulation (EU) 2024/1689) Timeline and roadmap

Use the phase dates to sequence evidence, owners, and build work.

This roadmap focuses on what should be operational in each phase, not only what the law says.

Author
Sorena AI
Published
Mar 4, 2026
Updated
Mar 4, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Mar 4, 2026
Updated Mar 4, 2026
Overview

A strong AI Act roadmap should reduce surprise. That means using the legal phasing to bring the right controls live in the right order: early prohibitions and literacy first, GPAI documentation next, and full high risk and transparency operating controls by the main application date.

Section 1

Phase 1: build the foundation

Start with inventory, roles, and classification. Without a clean register and a role matrix, every downstream workstream becomes slow and error prone. Foundation work also includes the evidence repository, the approval forum, and the first supplier documentation requests.

This phase should start as early as possible and should not wait for the first major legal date.

  • AI system and model inventory live.
  • Applicability and role workflow live.
  • Supplier evidence requests defined.
  • Decision record template and repository live.
Section 2

Phase 2: early obligations and guardrails

The first hard operating gates are Article 5 and AI literacy. Product teams, operations teams, and oversight roles should all understand what they are screening for and where escalation is mandatory. This phase also sets the tone for authority ready evidence later on.

If the foundation exists but the Article 5 gate does not, the program still has a dangerous hole.

  • Article 5 gate attached to intake and release.
  • AI literacy training assigned by role.
  • Escalation path documented for high concern cases.
  • Board or program level reporting on blocked or redesigned cases.
Section 3

Phase 3: GPAI and supplier readiness

This phase prepares for the 2 August 2025 Chapter V start date. Model providers need their Article 53 workflow and any systemic risk path. Integrators need contract and evidence leverage over upstream model suppliers.

Do not treat GPAI work as relevant only to frontier model labs. Many product teams rely on upstream models and still need supplier documentation, version notices, and incident support.

  • Article 53 documentation and publication workflow live.
  • Training content summary and copyright policy governance live.
  • Systemic risk threshold and notification path defined.
  • Upstream supplier clauses updated and tracked.
Section 4

Phase 4: high risk and transparency buildout

This is the deepest implementation phase because it reaches engineering design, testing, deployment, and operations. High risk systems need Articles 9 to 15 evidence, FRIA where required, and post market readiness. Transparency duties need actual product components, machine readable marking logic, QA evidence, and release review discipline.

By the time this phase ends, the organization should be able to show how the law is implemented in live systems, not only in policy documents.

  • High risk technical documentation and testing evidence complete.
  • FRIA and affected person information process live where required.
  • Article 50 components, copy, and marking logic in production.
  • Incident and corrective action workflows tested.
Section 5

Phase 5: transition cases and steady state operation

After the main application date, the roadmap becomes a portfolio management problem. Legacy GPAI models, public authority deployments, and Annex X transition cases need explicit tracking. At the same time, all production systems need recurring review because the Act is sensitive to changes in intended purpose, risk profile, and system design.

This is also where the program should mature into regular audit, management review, and corrective action loops.

  • Legacy GPAI models assigned to 2027 remediation plans.
  • Public authority and Annex X transition cases tracked to their longer deadlines.
  • Quarterly portfolio review linked to product and model change control.
  • Annual evidence readiness review and remediation plan.
Recommended next step

Turn EU AI Act (Regulation (EU) 2024/1689) Timeline and roadmap into an operational assessment

Assessment Autopilot can take EU AI Act (Regulation (EU) 2024/1689) Timeline and roadmap from reusing this material inside a governed evidence system to a reusable workflow inside Sorena. Teams working on EU AI Act (Regulation (EU) 2024/1689) can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Primary sources

References and citations

Related guides

Explore more topics

EU AI Act Applicability and Roles | Provider, Deployer, Importer Guide
Determine whether the EU AI Act applies, when output used in the Union brings a system into scope, and how to assign provider, deployer, importer.
EU AI Act Applicability Test | Scope, Role, and Obligation Routing
Run a practical EU AI Act applicability test that checks scope, exclusions, operator role, prohibited practices, high risk status, transparency triggers.
EU AI Act Checklist | Practical Compliance Checklist by Obligation
Use a detailed EU AI Act checklist covering inventory, role mapping, Article 5 screening, high risk controls, Article 50 disclosures, GPAI evidence, logging.
EU AI Act Compliance Program | Build an Operational AI Act Program
Build an EU AI Act compliance program that covers inventory, governance, AI literacy, prohibited practice gates, high risk controls, Article 50 product work.
EU AI Act Deadlines and Compliance Calendar | Exact Dates and Workplan
Track the exact EU AI Act dates, including entry into force on 1 August 2024, early obligations from 2 February 2025, GPAI obligations from 2 August 2025.
EU AI Act FAQ | Dates, High Risk, GPAI, Transparency, and Penalties
Get grounded answers to common EU AI Act questions on application dates, high risk status, provider versus deployer roles, transparency.
EU AI Act GPAI and Foundation Model Obligations | Chapter V Guide
Understand EU AI Act obligations for general purpose AI model providers, including Article 53 documentation, copyright policy.
EU AI Act High Risk AI Use Cases by Industry | Annex III and Product Routes
See how EU AI Act high risk status appears across biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration.
EU AI Act High Risk Requirements Checklist | Articles 9 to 15 and Beyond
Use a detailed high risk AI checklist covering Article 9 risk management, Article 10 data governance, Annex IV technical documentation, logging, instructions.
EU AI Act Penalties and Fines | Article 99 and GPAI Fine Exposure
Understand EU AI Act penalty tiers, including Article 5 fines up to EUR 35,000,000 or 7 percent.
EU AI Act Prohibited AI Practices | Article 5 Screening Guide
Screen AI systems against EU AI Act Article 5 prohibited practices, including manipulative and deceptive techniques, exploitation of vulnerabilities.
EU AI Act Requirements | Prohibited, High Risk, Transparency, and GPAI
Get a grounded overview of EU AI Act requirements across Article 5 prohibited practices, Article 6 and Annex III high risk systems.
EU AI Act Transparency, Labeling, and User Disclosures | Article 50 Guide
Implement EU AI Act Article 50 transparency duties for direct interaction notices, machine readable marking of synthetic outputs, deepfake disclosures.
EU AI Act vs ISO 42001 | What ISO 42001 Covers and What It Does Not
Compare the EU AI Act with ISO/IEC 42001:2023. Learn where ISO 42001 helps with AI policy, roles, risk assessment, impact assessment, documented information.
EU AI Act vs NIST AI RMF | How to Use AI RMF Without Missing AI Act Duties
Compare the EU AI Act with NIST AI RMF 1.0. Learn how the voluntary NIST AI RMF functions Govern, Map, Measure.