§ EU AI Act · Article 77
AI Act Article 77: Obligations, Deadlines & Penalties
At a glance
Article 77 of the AI Act imposes 7 obligations on Member State, market surveillance authority, national public authorities or bodies. At least one obligation carries an explicit compliance deadline.
§ Obligations
All obligations under Article 77
Obligation 1
National public authorities supervising fundamental rights must inform the market surveillance authority of any request for documentation made under this Article.
Regulation (EU) 2024/1689, Article 77, Article 77
- Obligated entity
-
national public authorities or bodies
- Action required
-
notify
- Deadline
-
—
- Penalty
-
—
Obligation 2
Each Member State shall identify the public authorities or bodies referred to in paragraph 1 and make a list of them publicly available.
Regulation (EU) 2024/1689, Article 77, Article 77
- Obligated entity
-
Member State
- Action required
-
identify
- Deadline
-
2 November 2024
- Penalty
-
—
Obligation 3
Each Member State shall make a list of the identified public authorities or bodies publicly available.
Regulation (EU) 2024/1689, Article 77, Article 77
- Obligated entity
-
Member State
- Action required
-
publish
- Deadline
-
2 November 2024
- Penalty
-
—
Obligation 4
Member States shall notify the list of identified public authorities or bodies to the Commission and to the other Member States.
Regulation (EU) 2024/1689, Article 77, Article 77
- Obligated entity
-
Member State
- Action required
-
notify
- Deadline
-
2 November 2024
- Penalty
-
—
Obligation 5
Member States shall keep the list of identified public authorities or bodies up to date.
Regulation (EU) 2024/1689, Article 77, Article 77
- Obligated entity
-
Member State
- Action required
-
maintain
- Deadline
-
—
- Penalty
-
—
Obligation 6
The market surveillance authority shall organise the testing of the high-risk AI system with the close involvement of the requesting public authority or body within a reasonable time following the request.
Regulation (EU) 2024/1689, Article 77, Article 77
- Obligated entity
-
market surveillance authority
- Action required
-
organise
- Deadline
-
within a reasonable time
- Penalty
-
—
Obligation 7
Any information or documentation obtained by national public authorities or bodies pursuant to this Article shall be treated in accordance with the confidentiality obligations set out in Article 78.
Regulation (EU) 2024/1689, Article 77, Article 77
- Obligated entity
-
national public authorities or bodies
- Action required
-
treat
- Deadline
-
—
- Penalty
-
—
§ Deadlines
EU AI Act compliance deadlines
-
2025-02-02
Article 5 prohibitions (unacceptable risk)
in_force
-
2025-02-02
Article 4 AI literacy
in_force
-
2025-08-02
GPAI model obligations (Articles 51 to 56)
in_force
-
2026-07-27
Regulation (EU) 2026/1744 (Digital Omnibus on AI) enters into force — AI Act applies as amended
in_force
-
2026-08-02
AI Act general date of application (Art 113) — governance, penalties and remaining provisions without a different date
in_force
-
2026-08-02
Article 50 transparency obligations (AI-interaction disclosure, labelling of deepfakes and AI-generated text, emotion-recognition notices)
in_force
-
2026-12-02
Article 50(2) machine-readable marking of AI-generated content — transition for generative AI systems placed on the market before 2 August 2026
scheduled
-
2026-12-02
NEW Article 5 prohibition: AI generation of non-consensual intimate imagery (NCII) and CSAM
scheduled
-
2027-08-02
National AI regulatory sandboxes: at least one operational per Member State (Art 57(1))
scheduled
-
2027-12-02
Annex III stand-alone high-risk obligations
scheduled
-
2028-08-02
Annex I embedded (regulated-product) high-risk obligations
scheduled
§ Frequently asked
Questions about Article 77
Who must comply with Article 77 of the AI Act?
+
Member State, market surveillance authority, national public authorities or bodies.
What does Article 77 of the AI Act require?
+
notify identify publish
What is the compliance deadline for AI Act Article 77?
+
2 November 2024; within a reasonable time