Key facts

  • High-risk obligations apply from 2 December 2027 for Annex III systems.
  • Annex I product-embedded high-risk obligations apply from 2 August 2028.
  • Both dates are confirmed by Regulation (EU) 2026/1744, effective 27 July 2026.
  • Preparation — inventory, classification, documentation — should start well before these dates.
  • Conformity assessment processes can take significant time to complete.

The confirmed timeline

Annex III high-risk obligations apply from 2 December 2027, with Annex I product-embedded obligations following from 2 August 2028. These dates are confirmed in Regulation (EU) 2026/1744.

Why preparation should start now

Conformity assessment, technical documentation and quality management systems for high-risk AI take significant time to build and cannot be assembled at the last minute. Organisations likely to be affected should begin their AI inventory and risk classification work well ahead of the deadlines, not close to them.

What to prioritise before the deadlines

Build or complete your AI system inventory, classify systems against the Annex III high-risk criteria, and identify which systems will need conformity assessment. This groundwork underpins everything that follows and takes considerably longer than most organisations expect.

Staying current on dates

The dates are now confirmed. Continue checking official guidance because implementing rules, standards and sector-specific expectations can still develop.

Frequently asked questions

When do high-risk AI obligations under the EU AI Act apply?

From 2 December 2027 for Annex III systems and 2 August 2028 for Annex I product-embedded systems, as confirmed by Regulation (EU) 2026/1744.

Are the high-risk AI deadlines confirmed?

Yes. Regulation (EU) 2026/1744 was published on 24 July 2026 and entered into force on 27 July 2026.

Why should preparation start before the deadlines?

Conformity assessment and documentation work takes significant time and cannot be completed at the last minute.

What should organisations prioritise first?

Building an AI system inventory and classifying systems against the Annex III high-risk criteria.

How often should the deadline timeline be checked?

Periodically, because implementing guidance and harmonised standards can still develop even though the dates are confirmed.

Related pages

Sources

Last updated 27 July 2026.