A 30-item readiness checklist for companies shipping AI into the EU — scope and classification, the August 2026 transparency duties, the GPAI vendor chain, and the high-risk runway to December 2027. Reflects the omnibus-amended timeline; paired with KVKK duties that bind today.
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Establish, feature by feature, where your product sits under the AI Act as amended by the omnibus package — before spending on any specific obligation.
SECTION 2 · 8 ITEMS
Transparency Duties — 2 August 2026
Article 50 was not postponed. These land in weeks, and they are product work, not paperwork.
SECTION 3 · 7 ITEMS
GPAI & the Vendor Chain
Your compliance rides on models you did not train. Make the chain contractual instead of assumed.
SECTION 4 · 7 ITEMS
High-Risk Runway & KVKK Now
KVKK binds today; the Annex III regime lands 2 December 2027. Use the runway deliberately.
Decision Matrix — Are We AI Act Ready?
How your checked items distribute shows your readiness maturity:
Section 1 at 7+/8: You know what you are. Classification is defensible in diligence.
Section 2 at 6+/8: August 2026 will pass quietly. Transparency is product-complete.
Section 3 at 5+/7: Your vendor chain is contractual, not assumed.
Section 4 at 5+/7: The December 2027 runway is planned, and KVKK exposure is closed.
Section 1 weak: Stop — everything else is guesswork until classification is done.
Section 2 weak in July 2026: This is the fire. Reprioritise the sprint.
All four above threshold: You are ahead of most of the market — document it and say so in diligence.
Legal notice. This checklist is for informational purposes only and does not constitute legal advice. The EU AI Act (as amended), KVKK and related frameworks referenced are general references; applying them to your company requires evaluation by a lawyer experienced in AI compliance. Vircon Legal: [email protected]
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