AI Act Article 89: Obligations, Deadlines & Penalties

All obligations under Article 89

Obligation 1

The AI Office may take necessary actions to monitor the effective implementation and compliance with the Regulation by providers of general-purpose AI models, including their adherence to approved codes of practice. Regulation (EU) 2024/1689, Article 89, Article 89

Obligated entity

AI Office

Sector scope

general-purpose AI models

Action required

monitor

Deadline

—

Penalty

—

Obligation 2

Downstream providers shall lodge a complaint that is duly reasoned and indicates the point of contact of the provider of the general-purpose AI model concerned. Regulation (EU) 2024/1689, Article 89, Article 89

Obligated entity

downstream provider

Sector scope

general-purpose AI models

Action required

notify

Deadline

—

Penalty

—

Obligation 3

Downstream providers shall include in their complaint a description of the relevant facts, the provisions of the Regulation concerned, and the reason why they consider the provider infringed the Regulation. Regulation (EU) 2024/1689, Article 89, Article 89

Obligated entity

downstream provider

Sector scope

general-purpose AI models

Action required

document

Deadline

—

Penalty

—

Obligation 4

Downstream providers shall include in their complaint any other information they consider relevant, including information gathered on their own initiative. Regulation (EU) 2024/1689, Article 89, Article 89

Obligated entity

downstream provider

Sector scope

general-purpose AI models

Action required

report

Deadline

—

Penalty

—

EU AI Act compliance deadlines

• 2025-02-02 Article 4 AI literacy in_force
• 2025-02-02 Article 5 prohibitions (unacceptable risk) in_force
• 2025-08-02 GPAI model obligations (Articles 51 to 56) in_force
• 2026-08-02 Article 50(2) machine-readable marking (watermarking) of AI-generated content provisionally_amended
• 2026-08-02 Article 50 transparency obligations OTHER than the 50(2) marking grace (for example disclosure that a user is interacting with an AI system) scheduled
• 2026-08-02 Annex III stand-alone high-risk obligations provisionally_amended
• 2026-08-02 National AI regulatory sandboxes (establishment deadline) provisionally_amended
• 2026-12-02 NEW Article 5 prohibition: AI generation of non-consensual intimate imagery (NCII) and CSAM provisionally_amended
• 2027-08-02 Annex I embedded (regulated-product) high-risk obligations provisionally_amended

Questions about Article 89

Who must comply with Article 89 of the AI Act? +

AI Office, downstream provider.

What does Article 89 of the AI Act require? +

monitor notify document