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EU AI Act applicability dates and your compliance runway

The EU AI Act phases in on a runway of dates rather than arriving all at once, and the platform tracks those dates for you instead of treating every obligation as due today. General-purpose AI and transparency obligations reached their applicability date on 2 August 2026. The Annex III high-risk obligations apply from 2 December 2027. So if you hold high-risk systems, you have runway to that date to close your evidence, which is a planning horizon, not an excuse.

The staggering is deliberate on the legislator's part. The Act's duties differ enormously in how much preparation they demand. Transparency duties, such as telling people they are interacting with an AI system, can be implemented quickly. The high-risk obligation set, with its documentation, risk management, and conformity work, takes sustained effort across several teams, and the later date reflects that. Reading the runway correctly therefore starts with knowing which of your systems fall on which track, which is what your risk classifications in the inventory determine.

Your obligation status view shows the distinction directly: it marks which items are already applicable now and which are still on the runway. That split is the practical planning input. Items already applicable deserve immediate attention, because for them the runway has ended. Items on the runway are where you choose your pace, and the record you build before the date is what makes the date a non-event.

How much runway is actually left is the question to keep asking, because evidence-building has lead times that are easy to underestimate. A full high-risk record means module runs across risk management, data governance, documentation, oversight, and more, each needing input from people with other jobs. Remediation of the gaps those runs find takes longer than the runs themselves. And if a conformity assessment involving a notified body is in your future, that process has its own duration you do not control. Working backwards from 2 December 2027 through those stages consumes the runway faster than the calendar suggests.

The platform's contribution is to keep the timeline attached to the work. Dates are tracked against your actual systems and obligations rather than in a memo nobody reopens, so the question 'what must be ready, and by when' always has a current answer drawn from your own record.

Treat the dates as planning milestones, and hold them lightly enough to re-verify. Applicability questions can turn on specifics: what you place on the market, when, in what role, and legislative timelines themselves can move. The platform reflects the dates as it understands them, and your obligation view reflects your position against them, but before you commit budgets or make representations that hinge on a date, confirm the current position with a qualified adviser. The runway is real; the discipline is using it to finish early rather than to start late.

A simple way to make the horizon concrete: take your highest-risk production system, list its outstanding items from the status view, and estimate the people-weeks each needs. Multiply across the inventory and the remaining calendar stops being abstract. Most organisations that do this exercise conclude they should start sooner than they had assumed, which is precisely the value of doing it. This is informational only and not legal advice: the platform's regulatory content is a scaffold pending qualified-professional review, so confirm any obligation with a qualified adviser before you rely on it.

EU AI Act applicability dates and your compliance runway | regulation10.com