The timeline is now an operating issue
The European Commission’s current timeline states that the AI Act entered into force on 1 August 2024 and became applicable, subject to exceptions, on 2 August 2026. Certain rules on prohibited practices and AI literacy applied earlier.
Compliance is therefore not only a legal memo. Product inventories, intended use, customer sector, human oversight and technical records now affect sales and delivery.
Identify your role
The same organisation may act as provider, deployer or distributor across different projects. Using a general-purpose model does not automatically transfer every obligation for the final system to the model provider.
- Is the system placed on the EU market or are its outputs used in the EU?
- Is it prohibited, high-risk, transparency-regulated or lower risk?
- Who determines the intended purpose?
- How do human oversight, logging and incident management work?
The first implementation file
Create a one-page use-and-risk record for every system: purpose, users, data, model, tools, permissions, human approval, tests, performance limits and accountable owner.
This does not replace legal classification, but it puts the facts needed for classification and review in one controlled place.