On August 1, 2024, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (the “AI Act”) entered into force. This officially kicks off the transition period for compliance. The length of the transition period will vary depending on the type of AI system:

• Most obligations under the AI Act, including the rules applicable to high-risk AI systems under Annex III and systems subject to specific transparency requirements will become applicable on August 2, 2026;
• Obligations applicable to prohibited AI systems and the obligations related to AI literacy will become applicable on February 2, 2025;
• Specific obligations applicable to general-purpose AI models will become applicable on August 2, 2025; and
• Obligations related to high-risk systems included in Annex I of the AI Act will become applicable on August 2, 2027.

Certain AI systems and models already on the market may be exempt or have longer compliance deadlines.

As the AI Act is a risk-based framework, compliance efforts will differ depending on the role of organizations in the AI value chain and the types of AI systems that they are developing or deploying. For example, providers of AI systems will generally have broader obligations then deployers and, thus, will likely need to allocate more time and resources to their AI compliance program. That said, with the official entry into force, it is important for organizations to analyze their exact exposure to the AI Act and start their compliance journey.

Read our client alert on an overview of the key obligations of the AI Act.

Read the AI Act.