Executive summary
What this means
Who this applies to
Regulatory context
Requirements
What organizations must do
- Determine your role system by system — provider, deployer, importer, distributor, or a combination — since the obligation set and deadline both follow from that classification.
- Classify each system's risk tier against the prohibited-practices list and the Annex III high-risk use-case list.
- For high-risk systems: Annex III track now has until 2 December 2027, Annex I product-embedded systems until 2 August 2028 — but start design/documentation work well ahead of the deadline.
- Don't wait for 2027/2028 to start compliance work — prohibited practices, AI literacy duties, GPAI obligations, and August 2026 transparency rules are already in force today.
Common mistakes
Treating "the AI Act" as a single deadline is a common and consequential mistake — different chapters have different application dates, and conflating them risks either premature over-investment in the wrong obligations or, more dangerously, missing an obligation that is already in force.
Organisations also sometimes assume their role is fixed — but the Act's substantial-modification and rebranding provisions mean a deployer can become a provider mid-lifecycle, which is worth checking whenever a system is materially changed or white-labelled.
A further common error is assuming the Digital Omnibus removed obligations rather than deferred them — the extended Annex III and Annex I dates give more time to prepare, but the underlying substantive requirements in Chapter III Section 2 are unchanged.
Open questions
- Whether the Digital Omnibus changed the wording of the core Article 3 definitions. The AI Act Service Desk's own page for Article 3 carries a Commission-authored notice stating the provision "has been amended by the Digital Omnibus on AI" and that "the text displayed on this page has not yet been updated to reflect those amendments." This article cites the pre-Omnibus definitions, independently confirmed via the same official source — but whether the Omnibus altered the precise wording of any core definition has not been confirmed and should be re-checked once the Service Desk's own update is published.
- How small mid-cap (SMC) treatment interacts with the provider/deployer distinction. Not yet fully documented in Commission guidance.
- Where the line sits between "deployer" and "provider" for an organisation that fine-tunes or customises a GPAI-based system. Not yet settled by further Commission guidelines or delegated acts.