Article 113 of the EU AI Act establishes a phased implementation timeline to allow businesses and regulators time to adapt. The regulation entered into force on 2 August 2024 but most provisions do not apply immediately. The timeline creates five distinct application dates based on the complexity and sensitivity of the obligations involved.
Phase-by-Phase Timeline
The first phase (6 months: 2 February 2025) activates the prohibited practices under Article 5, AI literacy obligations under Article 4, and supporting governance provisions. The second phase (12 months: 2 August 2025) activates GPAI model obligations in Chapter V and the governance framework including the AI Office and AI Board. The third phase (24 months: 2 December 2027) is the main application date for most obligations, including high-risk AI systems under Annex III. The fourth phase (36 months: 2 August 2028) activates obligations for high-risk AI systems falling under Annex I (product safety legislation). As amended by Regulation (EU) 2026/1744 (Digital Omnibus, in force 27 July 2026), Annex III high-risk obligations apply from 2 December 2027 and Annex I from 2 August 2028. Additional transitional provisions exist for AI systems already on the market before these dates.
Regulation (EU) 2024/1689 — Article 113
“This Regulation shall apply from 2 August 2026. However, Chapter I and II shall apply from 2 February 2025; Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 shall apply from 2 August 2025.”
| Date | Months After Entry Into Force | Provisions Applying |
|---|---|---|
| 2 February 2025 | 6 months | Art. 5 (prohibited practices), Art. 4 (AI literacy) |
| 2 August 2025 | 12 months | Chapter V (GPAI), AI Office and AI Board governance |
| 2 December 2027 | Amended | General application: Annex III high-risk systems (Regulation (EU) 2026/1744) |
| 2 August 2028 | Amended | Annex I product safety high-risk systems (Regulation (EU) 2026/1744) |
- AI systems already placed on the market before 2 August 2026 have limited transitional derogations
- Regulation (EU) 2026/1744 (Digital Omnibus, in force 27 July 2026) amends high-risk AI system deadlines to 2 December 2027 (Annex III) and 2 August 2028 (Annex I)
- Notified bodies must be designated before the third-phase conformity assessment obligations can function
- The EU AI Act database for high-risk AI systems must be operational by 2 August 2026