AI Act Article 96: Obligations, Deadlines & Penalties

All obligations under Article 96

Obligation 1

The Commission shall develop guidelines on the practical implementation of the Regulation, covering application of requirements, prohibited practices, substantial modification, transparency obligations, relationship with other Union law, and the definition of an AI system. Regulation (EU) 2024/1689, Article 96, Article 96

Obligated entity

Commission

Action required

develop

Deadline

—

Penalty

—

Obligation 2

When issuing guidelines, the Commission shall pay particular attention to the needs of SMEs including start-ups, local public authorities, and sectors most likely to be affected by the Regulation. Regulation (EU) 2024/1689, Article 96, Article 96

Obligated entity

Commission

Action required

pay attention

Deadline

—

Penalty

—

Obligation 3

The guidelines shall take due account of the generally acknowledged state of the art on AI, as well as relevant harmonised standards and common specifications referred to in Articles 40 and 41 or set out pursuant to Union harmonisation law. Regulation (EU) 2024/1689, Article 96, Article 96

Obligated entity

Commission

Action required

take due account

Deadline

—

Penalty

—

Obligation 4

At the request of Member States or the AI Office, or on its own initiative, the Commission shall update previously adopted guidelines when deemed necessary. Regulation (EU) 2024/1689, Article 96, Article 96

Obligated entity

Commission

Action required

update

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 96

Who must comply with Article 96 of the AI Act? +

Commission.

What does Article 96 of the AI Act require? +

develop pay attention take due account