August 2, 2026 is a fixed date. It follows directly from
Article 113 of the EU AI Act, which sets high-risk AI system obligations
at 24 months after the Act’s August 1, 2024 entry into force.
Organizations deploying AI systems in categories listed under Annex III,
covering critical infrastructure, education, employment, essential services,
law enforcement, and immigration, must meet those obligations by that date
or face penalties.
On March 5, 2026, the European Commission published the second draft of its
Code of Practice on Marking and Labelling of AI-generated content.
This is the most current official implementation guidance on transparency
requirements, which also take effect August 2. Compliance teams should be
incorporating this draft into their planning now.
Penalties for high-risk AI system violations reach up to €15 million or
3% of global annual turnover under
Article 99 of the Act. The €35 million / 7% ceiling you may have seen
cited applies specifically to prohibited AI practice violations, a different,
more severe category. Know which tier applies to your systems.
Some legal commentary reports that amendments under discussion in EU
legislative bodies could potentially extend the high-risk rules deadline
to December 2027. Those amendments have not been adopted. No compliance
planning should rely on an extension that may not materialize.
*Consult qualified legal counsel to determine whether your specific AI
systems fall under Annex III and to assess your documentation, registration,
and conformity assessment obligations before August 2, 2026.*