The EU AI Act is entering its most consequential implementation phase. High-risk AI system provisions take effect in October 2026 under the Act’s staggered application schedule, and compliance teams now face a structural problem: the national competent authorities who will handle enforcement aren’t all in place, and the harmonized standards that define what “compliant” looks like aren’t finalized.
Under Article 70 of the EU AI Act, each member state must establish or designate at least one national competent authority to oversee the regulation’s application. Progress varies. Early tracking from policy researchers indicates that implementation is uneven across member states – some have moved faster than others, though no official EU-wide status registry has been published. That variation matters for companies operating across multiple EU jurisdictions: your enforcement exposure depends partly on which national authority is watching.
The standards gap is equally significant. The European Commission’s AI Act portal confirms that harmonized standards are under active development through CEN-CENELEC. These standards will be the primary mechanism for conformity assessment, meaning organizations building or deploying high-risk AI systems can’t finalize their compliance architecture until the standards are published. The Commission has framed standardization as the legal certainty instrument for the Act. That certainty isn’t here yet.
The broader timeline runs through 2027. Article 113 of the EU AI Act establishes a phased application schedule that extends past October 2026. High-risk provisions are the immediate focus, but organizations with exposure across multiple AI system categories need to track both waves.
For compliance teams, the practical reality is this: the October 2026 deadline is fixed, the standards aren’t finalized, and the national authority in your jurisdiction may still be standing up. That’s not a reason to wait. It’s a reason to build your compliance architecture against the official text now and adjust as standards are published.