Timeline & Deadlines
Phased Applicability
The AI Act becomes applicable in stages. The following deadlines are operationally relevant for the BAUER GROUP:
| Date | Obligation | Status | BAUER GROUP Relevance |
|---|---|---|---|
| 01.08.2024 | Entry into force | ✅ Completed | Preparation phase |
| 02.02.2025 | Prohibited AI practices (Art. 5) + AI Literacy (Art. 4) | ✅ Applicable | Review of all products against the prohibition catalogue |
| 02.08.2025 | GPAI obligations (Art. 51–56), governance infrastructure, sanctions regime | ✅ Applicable | Relevant only as GPAI deployer |
| 02.08.2026 | Transparency obligations (Art. 50) | ⏳ Deadline | Disclosure duties for chatbots and AI-generated content |
| 02.12.2026 | Marking of synthetic content (Art. 50(2)) + new prohibition NCII/CSAM (Art. 5) | ⏳ Transitional deadline | Machine-readable labelling of AI-generated outputs |
| 02.12.2027 | High-risk AI systems Annex III (stand-alone, Art. 6(2)) | ⏳ Deadline (Omnibus) | Main deadline – all high-risk systems must be compliant |
| 02.08.2028 | High-risk AI as safety components in regulated products (Annex I) | ⏳ Deadline (Omnibus) | Embedded AI in machinery, medical devices etc. |
Digital Omnibus – Postponed High-Risk Deadlines (as of June 2026)
The European Commission's original "Digital Omnibus" proposal (19 Nov 2025) became a provisional agreement between Parliament and Council on 7 May 2026. It postpones the high-risk obligations to fixed dates (without the originally proposed standards trigger):
- Annex III (stand-alone high-risk systems): 02.08.2026 → 02.12.2027
- Annex I (embedded in regulated products): 02.08.2027 → 02.08.2028
Not postponed: GPAI obligations, AI literacy, the existing prohibitions (Art. 5) and the transparency obligations under Art. 50 (still 02.08.2026); only the marking of synthetic content under Art. 50(2) receives a grace period until 02.12.2026.
Legal status: The agreement is not yet published in the EU Official Journal. Until formal adoption, the dates 02.08.2026 and 02.08.2027 formally remain in force. BAUER GROUP plans along the postponed dates, keeps 02.08.2026 as the legal fallback in view and tracks the formal adoption.
Operative Timeline BAUER GROUP
Already Completed (Q1 2025)
- AI Literacy: foundational training for all employees with AI exposure
- Review of the product portfolio against the prohibition catalogue (Art. 5)
- Creation of AI system inventory (draft)
Ongoing (2025–2026)
- Risk classification of all identified AI systems
- Go/No-Go assessment for high-risk candidates
- Development of transparency notices for limited-risk systems
- Documentation of this compliance site
Deadline 02.08.2026 – Transparency
- Disclosure duties for AI interaction (chatbots) implemented
- Machine-readable labelling of AI-generated content prepared (mandatory from 02.12.2026)
Deadline 02.12.2027 – High-Risk (Annex III)
- Conformity assessment for all high-risk systems (where a Go decision has been taken)
- EU database registration
- CE marking
- QMS evidence