EU AI Act: Timeline & Phased Implementation (Article 113)
Implementation Timeline [Art 113]
Rule: The AI Act applies in phases, with different rules taking effect at different times.
Key dates
| Date | What happens | Citation |
|---|---|---|
| 1 August 2024 | Entry into force | Art 113 |
| 2 February 2025 | Prohibited AI practices banned | Art 113(a) |
| 2 August 2025 | GPAI model rules apply | Art 113(b) |
| 2 August 2025 | Governance provisions apply | Art 113(b) |
| 2 August 2026 | Full application (most provisions) | Art 113 |
| 2 August 2027 | High-risk AI in Annex I (regulated products) | Art 113(c) |
Phase 1: February 2025 (6 months)
Prohibited AI systems become illegal:
| Prohibited practice | Details | Citation |
|---|---|---|
| Subliminal manipulation | Beyond person’s consciousness | Art 5(1)(a) |
| Exploiting vulnerabilities | Age, disability, social/economic situation | Art 5(1)(b) |
| Social scoring | By public authorities | Art 5(1)(c) |
| Predictive policing | Based solely on profiling | Art 5(1)(d) |
| Untargeted facial scraping | For facial recognition databases | Art 5(1)(e) |
| Emotion inference | In workplace and education | Art 5(1)(f) |
| Biometric categorisation | For sensitive characteristics | Art 5(1)(g) |
| Real-time remote biometric ID | In public, by law enforcement (with exceptions) | Art 5(1)(h) |
Phase 2: August 2025 (12 months)
| What applies | Details | Citation |
|---|---|---|
| GPAI model obligations | Transparency, documentation, copyright | Arts 51-56 |
| Systemic risk models | Additional requirements for high-capability models | Art 51 |
| Penalties for prohibited AI | Up to €35M or 7% turnover | Art 99 |
| AI Office | Operational | Art 64 |
| National authorities | Must be designated | Art 70 |
Phase 3: August 2026 (24 months)
Full application of:
| What applies | Details | Citation |
|---|---|---|
| High-risk AI requirements | For Annex III high-risk systems | Arts 8-15 |
| Transparency obligations | Disclosure requirements | Art 50 |
| Registration database | EU database operational | Art 71 |
| Conformity assessment | Required for high-risk | Art 43 |
| All penalties | Full enforcement | Art 99 |
Phase 4: August 2027 (36 months)
| What applies | Details | Citation |
|---|---|---|
| Annex I high-risk systems | AI in regulated products (medical devices, machinery, etc.) | Art 6(1) |
Existing AI systems
| Situation | Transition period | Citation |
|---|---|---|
| GPAI models on market | 12 months to comply | Art 111(3) |
| High-risk systems already on market | Continue until significantly changed | Art 111(1) |
| Public authorities | Until 2 August 2030 | Art 111(2) |
Source Text
Article 113: This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.
It shall apply from 2 August 2026.
However:
(a) Chapters I and II shall apply from 2 February 2025;
(b) Chapter III Section 4, Chapter V, Chapter VII, and Chapter XII and Article 78 shall apply from 2 August 2025, with the exception of Article 101;
(c) Article 6(1) and the corresponding obligations in this Regulation shall apply from 2 August 2027.
Article 111(1): This Regulation shall not apply to the AI systems which are components of the large-scale IT systems established by the legal acts listed in Annex X that have been placed on the market or put into service before 2 August 2027, unless the replacement or amendment of those legal acts leads to a significant change in the design or intended purpose of the AI system or AI systems concerned.
Citation
Article 113, EU AI Act | Article 111