EU AI Act dates for AI agents: what applies now, and what comes next

The AI Act applies in stages. The bans in Article 5 apply since 2 February 2025. The transparency duties in Article 50 apply since 2 August 2026. New bans on intimate deepfakes and child sexual abuse material apply from 2 December 2026. High-risk duties for Annex III uses, such as hiring and staff monitoring, apply from 2 December 2027.

The dates

DateWhat appliesWho it falls onOfficial Journal text
2 February 2025Chapters I and II, including the bans in Article 5Everyone who places on the market, puts into service or uses an AI systemArt. 113, third paragraph, point (a): "Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026;"
2 August 2025Duties for general-purpose AI models (Chapter V)Providers of general-purpose AI modelsArt. 113, third paragraph, point (b): "Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 shall apply from 2 August 2025, with the exception of Article 101;"
27 July 2026The Digital Omnibus on AI, Regulation (EU) 2026/1744, enters into forcen/aPublished in the Official Journal on 24 July 2026; in force on the third day after publication
2 August 2026The Regulation in general, including the transparency duties in Article 50Providers and deployers named in Article 50Art. 113, second paragraph: "It shall apply from 2 August 2026."
2 August 2026Fines for providers of general-purpose AI models (Article 101)Providers of general-purpose AI modelsArt. 101 is excluded from point (b) above, so the general date applies
2 December 2026New bans: Article 5(1), points (ba) and (bb), and Article 5(1a) and (1b)Everyone who places on the market, puts into service or uses such a systemArt. 113, third paragraph, point (a), quoted above
2 December 2026Machine-readable marking (Article 50(2)) for generative systems already on the market before 2 August 2026Providers of those systemsArt. 111(4): "Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, that have been placed on the market before 2 August 2026 shall take the necessary steps in order to comply with Article 50(2) by 2 December 2026."
2 August 2027General-purpose AI models placed on the market before 2 August 2025Their providersArt. 111(3): "Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027."
2 December 2027High-risk duties for Annex III uses, including point 4: employment, workers' management and access to self-employmentProviders and deployers of those systemsArt. 113, third paragraph, point (c)(i): "2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III; and"
2 August 2028High-risk duties for AI in products covered by Annex IProviders and deployers of those systemsArt. 113, third paragraph, point (c)(ii): "2 August 2028 as regards AI systems classified as high-risk pursuant to Article 6(1) and Annex I;"

What this means for AI agents

  • The Article 5 bans already apply to every agent placed on the EU market or used in the EU, whatever its size.
  • If your agent talks to people, Article 50 may apply now.
  • If your agent helps hire, rank, assign or monitor staff, the high-risk duties may apply from 2 December 2027.

Change log

  • 27 July 2026: Regulation (EU) 2026/1744 in force. It moved Annex III high-risk duties from 2 August 2026 to 2 December 2027, added new bans from 2 December 2026, and gave older generative systems until 2 December 2026 for Article 50(2) marking.
  • 28 October 2026: checked for corrections published after the 27 July 2026 consolidated text. No date changed.

Sources:

As of 28 October 2026. This page explains the text of the Act. It is not legal advice.