Istanbul, July 2026. If you have seen the headlines saying the EU AI Act was “delayed” and quietly moved it down your list: read this before 2 August. The postponement is real — but it does not cover the obligations most likely to apply to your product this summer.
What was actually postponed
Under the EU’s late-2025 “digital omnibus” agreement, the compliance deadlines for high-risk AI systems moved: use-based high-risk systems under Annex III (recruitment, credit scoring, education, critical infrastructure and similar) now apply from 2 December 2027, and product-embedded high-risk systems under Annex I (medical devices, machinery, radio equipment) from 2 August 2028.
That is genuine relief if you are building in those categories. It is not a general delay of the AI Act.
What still happens on 2 August 2026
The Act’s general application date stands. Most importantly for technology companies, the Article 50 transparency obligations were not deferred. From 2 August 2026:
- AI interaction disclosure. Users must be informed when they are interacting with an AI system — your AI support chat, sales assistant or voice agent must say so, unless it is obvious from context.
- Synthetic content marking. AI-generated or AI-manipulated audio, image, video and text content must be marked as such in a machine-readable form. If you generate content at scale — gaming assets, marketing creatives, avatars — this is your problem.
- Deepfake labelling. Content that resembles real persons, places or events must be visibly disclosed as artificially generated.
- Emotion recognition and biometric categorisation disclosure to exposed persons.
Member state penalty and governance regimes also apply from the same date. Transparency violations carry fines of up to EUR 15 million or 3% of global annual turnover; the prohibited-practice tier (up to EUR 35 million or 7%) has already been live since February 2025.
“But we are a Turkish company”
The AI Act reaches beyond the EU. It applies to providers placing AI systems on the EU market wherever established — and to providers and deployers located in third countries where the output of the system is used in the EU. A Turkey-based SaaS with EU customers, a game studio with EU players, an e-commerce platform serving EU consumers with an AI chat layer: all plausibly in scope, with no EU subsidiary required.
Your 30-day checklist
- Inventory every point where an EU user interacts with AI in your product (chat, voice, recommendations presented as human).
- Add clear AI-interaction disclosures to conversational interfaces.
- Implement machine-readable marking for AI-generated media you publish or let users generate.
- Add visible labels to any content that qualifies as a deepfake.
- Document which of your features rely on third-party general-purpose models — your marking obligations often ride on their tooling.
None of this requires a conformity assessment or a notified body. It requires product decisions, made before 2 August.
For scope questions — including whether the December 2027 high-risk timeline applies to your roadmap — see our AI & Algorithm Law practice, or start with the glossary entries on high-risk AI systems and the EU AI Act.
The timeline after the omnibus, in one table
| Date | What applies | Postponed? |
|---|---|---|
| 2 Feb 2025 | Prohibited practices + AI literacy duty | No — binding since then |
| 2 Aug 2025 | GPAI model rules | No |
| 2 Aug 2026 | Article 50 transparency + member-state penalty framework + GPAI enforcement | No — live now |
| 2 Dec 2027 | Annex III high-risk regime + FRIA for named deployers | Yes — moved from Aug 2026 |
| 2 Aug 2028 | Annex I product-embedded high-risk obligations | Yes — moved from Aug 2027 |
Does the postponement give us a free pass until 2027?
No — four layers already bind: the bans, AI literacy, GPAI rules and Article 50 transparency, with penalties live since August 2026. The postponement moved exactly one thing: the Annex III/I high-risk machinery.
What is the smartest use of the extra time?
Classification and evidence: run the classification memo now, join a regulatory sandbox if Annex III is in your future, and let documentation accumulate — December 2027 rewards the companies that treated the runway as runway.
This week’s homework
Take the table above and mark each row green, yellow or red for your own product. Two minutes of honesty; the yellow cells are your Q3 backlog.
This article is for general information only and does not constitute legal advice. Regulatory dates reflect the position as of July 2026; the EU legislative process may move them again.
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