Deadlines

What Changes on 2 August 2026 Under the EU AI Act

Updated 19 July 2026 8 min read

2 August 2026 is the EU AI Act's next hard date — but after the 2026 Digital Omnibus, it is a very different date than originally planned. The Article 50 transparency obligations and the Commission's GPAI enforcement powers apply from that day; the high-risk (Annex III) obligations do not — they moved to December 2027. This guide separates what actually lands on 2 August from what was postponed, and tells you who must do what now.

What applies from 2 August 2026

Two things become enforceable on 2 August 2026:

  • Article 50 transparency obligations. AI systems that interact with people (chatbots, voice assistants) must disclose they are AI. Providers of systems generating synthetic audio, image, video or text must mark outputs as artificially generated in a machine-readable format (Art. 50(2)). Deepfakes must be visibly labeled. And people exposed to emotion recognition or biometric categorisation must be informed.
  • GPAI enforcement powers (Article 101). The Commission's power to fine general-purpose AI model providers activates. GPAI obligations themselves have applied since 2 August 2025 — what changes now is that breaching them can cost up to €15M or 3% of worldwide turnover.

Article 50 breaches sit in the same €15M / 3% tier under Article 99(4). Check where you stand in two minutes with the Article 50 readiness checker.

What does NOT apply: the Digital Omnibus postponement

Under the Act as adopted in 2024, 2 August 2026 was also meant to be the big high-risk date — the day the full Annex III obligations (risk management, data governance, Annex IV documentation, human oversight and the rest) became enforceable. That is no longer the case.

The Digital Omnibus, the EU's simplification package amending several digital laws at once, was formally adopted and signed on 8 July 2026. For the AI Act, its headline change is timing: obligations for Annex III high-risk systems moved to 2 December 2027, and those for high-risk systems that are safety components of regulated products (Annex I) to 2 August 2028. The stated rationale was that the standards and conformity-assessment infrastructure providers need — harmonised standards, notified bodies, national guidance — were not ready at scale, and enforcing against companies with no practical route to conformity would have been counterproductive.

What the Omnibus did not do is soften the substance. The Article 9–15 requirements are unchanged, the prohibited-practices list is unchanged, and the dates that had already passed (prohibitions from February 2025, GPAI duties from August 2025) were untouched. Article 50 and GPAI enforcement stayed on 2 August 2026. The postponement buys high-risk providers time; it does not buy anyone out of the transparency layer.

One transition to know: content marking until 2 December 2026

Within Article 50 there is a single grace period: providers of generative systems that were already on the market get until 2 December 2026 to implement machine-readable output marking under Art. 50(2). Everything else in Article 50 — chatbot disclosure, deepfake labels, emotion-recognition notices — applies in full from 2 August 2026, and new systems must mark outputs from day one. See the AI content-marking guide for how to actually implement marking.

Who must do what now

By operator type:

  • Anyone running a customer-facing chatbot or AI assistant in the EU — add a clear "you are talking to AI" disclosure before 2 August 2026. This is the cheapest duty in the Act and the easiest to spot-check from outside.
  • Providers of generative AI features (image, video, audio or text generation) — implement machine-readable marking (C2PA/provenance metadata or watermarking). Already on the market? You have until 2 December 2026. Shipping after 2 August 2026? Mark from launch.
  • Anyone publishing deepfakes — visible labels, not just metadata.
  • Users of emotion recognition or biometric categorisation — inform affected people, and check Article 5 first: workplace and education uses of emotion recognition are prohibited outright.
  • GPAI model providers — your Articles 53–55 duties are now backed by €15M / 3% fines; documentation, copyright policy and training-data summaries need to be genuinely in place.
  • High-risk (Annex III) providers and deployers — your deadline is 2 December 2027, but an Article 9–15 programme takes months to build. Use the breathing room; don't waste it.

Start with the Article 50 readiness checker for the transparency layer, then classify your full system to see everything else that applies.

Frequently asked questions

Did the Digital Omnibus delay the whole EU AI Act?

No. It moved the high-risk deadlines — Annex III to 2 December 2027 and Annex I product-safety systems to 2 August 2028 — but left everything else intact. Prohibitions (Feb 2025), GPAI duties (Aug 2025), Article 50 transparency and GPAI enforcement (2 Aug 2026) all stand.

What is the penalty for missing the 2 August 2026 transparency duties?

Article 50 breaches fall in the middle tier of Article 99: up to €15 million or 3% of worldwide annual turnover, whichever is higher (for SMEs, the lower). The same ceiling applies to GPAI providers under Article 101 from the same date.

My generative AI product is already live — do I need marking by 2 August 2026?

Systems generating synthetic content that were already on the market have a transition until 2 December 2026 to implement machine-readable marking under Art. 50(2). The other Article 50 duties that touch you — such as deepfake labels — still apply from 2 August 2026.

Does 2 August 2026 matter if my system is high-risk?

Yes, doubly. Your high-risk obligations now land on 2 December 2027, but Article 50 applies to you too where relevant from 2 August 2026 — a high-risk system with a conversational interface still needs the AI disclosure, and any synthetic output still needs marking.

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Still have questions about how this applies to you? Talk to us — we're happy to help.