Question 1

When does the EU AI Act fully apply?

Accepted Answer

Application is phased. Prohibited practices have applied since February 2025 and GPAI model obligations since August 2025. Article 50 transparency obligations apply from 2 August 2026. Under the Digital Omnibus amendment (agreed 7 May 2026, European Parliament-approved 16 June 2026), high-risk obligations are deferred: stand-alone Annex III systems and FRIA to 2 December 2027, and product-embedded Annex I systems to 2 August 2028. These deferrals take legal effect once the amendment is published in the Official Journal; until then the original dates remain the binding law.

Question 2

What is the FRIA deadline under the EU AI Act?

Accepted Answer

Under the Digital Omnibus amendment the Fundamental Rights Impact Assessment (FRIA) deadline moves to 2 December 2027, tracking the deferred Annex III high-risk obligations. It applies to public bodies, public service providers, and credit or insurance deployers using high-risk AI systems listed in Annex III. The change takes legal effect on publication of the amendment in the Official Journal; until then the original 2 August 2026 date remains in law.

Question 3

When do GPAI obligations apply?

Accepted Answer

General-purpose AI model obligations under Articles 53-55 have applied since 2 August 2025. All GPAI model providers placing models on the EU market must comply with technical documentation, copyright policy, and training data summary requirements.

Question 4

What are the penalties for non-compliance with the EU AI Act?

Accepted Answer

Penalties reach up to EUR 35 million or 7% of global annual turnover for prohibited practice violations under Article 5. Other infringements carry fines up to EUR 15 million or 3% of turnover. SME economic viability must be considered.

Question 5

Which AI practices are already banned under the EU AI Act?

Accepted Answer

Eight AI practices have been banned since 2 February 2025 under Article 5: subliminal manipulation, exploitation of vulnerabilities, social scoring, predictive policing based on profiling, untargeted facial image scraping, workplace and education emotion recognition, biometric categorisation for sensitive attributes, and real-time remote biometric identification in public spaces.

Question 6

Will the Digital Omnibus change EU AI Act deadlines?

Accepted Answer

Yes. The Digital Omnibus on AI was provisionally agreed on 7 May 2026 and approved by the European Parliament in plenary on 16 June 2026 (423 in favour). It defers the high-risk obligations to 2 December 2027 (Annex III, including FRIA) and 2 August 2028 (Annex I), adds a new Article 5 ban on nudifier and CSAM tools, and simplifies several obligations. Formal Council adoption and publication in the Official Journal are still pending; until publication the original AI Act dates remain the binding law, so organisations should continue preparing.

EU AI Act Compliance Timeline

Take this timeline with you

Entry into Force

Prohibited AI Practices & AI Literacy

GPAI, Governance, Notified Bodies & Penalties

Commission Guidelines & Templates

Transparency Obligations (Article 50)

New Prohibition & Watermarking Grace Ends

Legacy GPAI Compliance & National Sandboxes

High-Risk (Annex III) & FRIA

High-Risk Embedded in Products (Annex I)

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