[ MSP.DD ] For investors and founders · Updated
When do the EU AI Act high-risk rules apply?
Short answer
Under the Digital Omnibus agreed in May 2026, obligations for stand-alone high-risk systems in Annex III move from 2 August 2026 to 2 December 2027, and for high-risk AI built into regulated products (Annex I) from 2 August 2027 to 2 August 2028. Article 50 transparency duties stay on 2 August 2026. Check the final text in the Official Journal before relying on these dates.
Why it matters
The delay changes the timing of compliance cost, not the size of it. In due diligence, a target that used the extra time to build documentation is worth more than one that stopped.
What to do with it
- 01Classify the product against Annex III and Annex I.
- 02Check the Article 50 transparency duties, which are not delayed.
- 03Use the extra time to build the required documentation, not to postpone it.
- 04Re-check the dates against the Official Journal text before closing.
Red flags
- Treating the delay as a reason to skip classification.
Good signs
- A compliance plan with dates tied to the new deadlines.
The numbers
- Annex III stand-alone high-risk obligations move to 2 December 2027, and Annex I product-embedded obligations to 2 August 2028. Article 50 proceeds as scheduled on 2 August 2026, with a grace period until 2 December 2026 for watermarking by systems already on the market. [1]