EU delays compliance deadlines for the AI Act

The compliance deadlines for the European Union's (EU) new cross-sector legislation on artificial intelligence (AI) have been revised following a delay in publication, notwithstanding that the text is settled.

EU officials have recently confirmed to Osborne Clarke that the final step in this process – the publication of the definitive text in the EU's Official Journal – has been delayed until mid-July, with some commentators suggesting 12 July.

Late summer 2024

The AI Act will become binding law 20 days after it is published in the Official Journal; because of the publication delay, this is now expected to be in early August.

The delay will allow businesses more time to understand and digest upcoming compliance obligations as well as forthcoming guidance from the AI Office.

Revised compliance deadlines

Since the deadlines in the staggered implementation and compliance timetable flow from the date of publication in the Official Journal, they have each been pushed back by several weeks.

Early 2025

Prohibitions on unacceptable risks come into force.

General provisions on subject matter, scope, definitions and AI literacy come into force.

Late summer 2025

The provisions on general-purpose AI come into force.

Provisions dealing with governance, conformity bodies, enforcement, confidentiality and penalties come into force.

Late summer 2026

All other provisions come into force, including regulation of high-risk AI systems listed in (but not AI systems within the EU product safety regulation regime, listed in annex I).

Late summer 2027

Regulation of high-risk systems within the EU product safety regulation regime (listed in annex I) come into force.

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The AI Office

 The AI Office (a unit within the European Commission) has already been launched and is starting its role as an EU centre of AI expertise. It will play a key role in implementation of the AI Act, including meeting requirements in the legislation for guidelines and codes of practice.

It also, informally, offers businesses a forum to discuss queries about the interpretation and application of the AI Act's provisions to particular AI systems.

What else should businesses be considering?

There are many other areas of legal and regulatory risk around the development and deployment of AI systems that may be in play, which are explained in our overview on what risks businesses need to consider when using AI.

If you would like to discuss any of the issues raised in this article, please do not hesitate to contact the authors or your usual Osborne Clarke contact and see our other Insight on this topic and artificial intelligence more generally.