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Regulation Daily Brief

EU AI Act Committee Vote Tomorrow: Council's Conditional Trigger Changes How Compliance Timelines Work

1 min read IAPP Partial
The EU AI Act amendment process hits a decision point tomorrow, March 18, when MEPs vote on a preliminary political agreement reached last week. The Council's negotiating position adds a wrinkle compliance teams haven't seen before: a conditional trigger mechanism that would replace fixed calendar deadlines with obligation dates tied to an external condition.

Two tracks of EU AI Act amendment activity converged this week. MEPs reached a preliminary political agreement on March 11, during a shadow meeting focused on the Digital Omnibus package. A committee vote is scheduled for March 18. Separately, the Council adopted its negotiating position on March 13.

The MEP agreement and Council position both address high-risk compliance deadlines. According to multiple analyses of the draft text, including a review by Arnold Porter, the proposed amendments would extend deadlines to December 2, 2027 for Annex III systems and August 2, 2028 for Annex I systems. These dates are reported across several sources but haven’t been confirmed in official published legislative text. Treat them as proposed, not settled.

The Council’s position goes further. According to analyses of the Council’s March 13 negotiating position, the proposal would decouple fixed calendar dates from high-risk compliance obligations, introducing a conditional trigger and a backstop date. The full mechanism isn’t yet publicly available in primary text. What it means practically: compliance teams can’t simply mark a date. They’d need to monitor whether the trigger condition is met.

Tomorrow’s vote doesn’t enact anything. It advances the MEP position toward trilogue with the Council. The gap between the two positions still needs resolution before any deadline extension becomes law.

For context on where this fits within the broader amendment package, see our analysis of the Council’s three-track package and the compliance implications of the MEP agreement. We’ll have follow-up coverage after the vote.

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