Who this applies to
The AI Act applies to providers (Article 2(2)), deployers (Article 2(3)), importers (Article 2(4)), and distributors (Article 2(5)) of AI systems, as well as product manufacturers placing AI systems on the EU market (Article 4(1)). The obligations extend to public authorities using high-risk AI (Article 3(1)) and third-party conformity assessment bodies (Article 43).What is required
- Prohibit AI practices listed in Article 5 (e.g., social scoring, manipulative subliminal techniques, exploitation of vulnerabilities) – effective February 2025 (Article 5(1)).
- Register high-risk AI systems in the EU database (Article 60(1)) before placement on the market or use.
- Conduct conformity assessments for high-risk AI systems (Article 43(1)) and maintain technical documentation (Article 11(1)).
- Implement risk management systems (Article 9) and data governance measures (Article 10) for high-risk AI.
- Report serious incidents to market surveillance authorities (Article 62(1)) within 15 days of detection.
- Comply with transparency obligations for limited-risk AI (e.g., deepfakes, emotion recognition) under Article 52.
Key deadlines
Under Article 113 as written, the Article 99 penalty provisions apply from August 2, 2026. The Digital Omnibus provisional agreement of 7 May 2026 moves Annex III high-risk obligations to 2 December 2027, pending formal adoption; until Official Journal publication, the original dates remain law.Enforcement patterns
AI Act Article 50 transparency obligations take effect 2 August 2026. Annex III high-risk obligations are expected 2 December 2027, pending formal adoption of the Digital Omnibus (political agreement of 7 May 2026). No AI Act enforcement precedent currently exists. This page will be updated as enforcement cases emerge.Cross-border considerations
Data indicates Austria (AT) and Spain (ES) have early engagement with AI Act enforcement mechanisms, as evidenced by citations of Article 99 in national guidance. No jurisdiction-specific enforcement patterns are yet verifiable beyond these references.Fontvera also analyses closely related obligations, including [AI Act Article 70 for the Commission](/intelligence/ai-act-art-70-commission-obligations), [AI Act exemptions FAQ](/intelligence/ai-act-faq-exemptions), [AI Act timeline FAQ](/intelligence/ai-act-faq-timeline), and [AI Act Annex IV technical documentation](/intelligence/ai-act-technical-documentation-annex-iv).