Regulatory deadlines

AI Act: marking of synthetic content for systems already on the market

Providers of systems generating text, images, audio or video placed on the market before 2 August 2026 have until 2 December 2026 to mark outputs as artificially generated (Article 50(2)). Systems placed on the market from 2 August 2026 must mark them straight away.

Who it applies to: Providers of generative AI systems, including general-purpose ones.

AI Act: new prohibitions on intimate imagery and child sexual abuse material

It becomes prohibited to place on the market, put into service or use AI systems that generate or manipulate realistic intimate images, video or audio of identifiable people without their consent, or child sexual abuse material (Article 5(1), points (ba) and (bb)). For providers the prohibition applies where this is the intended purpose, or where the output is reasonably foreseeable and adequate technical safeguards are lacking; for deployers, where they use the system to generate such material (Article 5(1a)).

Who it applies to: Providers and deployers of AI systems that generate images, video or audio.

National councils of professional bodies: CPD rules to include AI courses

The national councils of Italian professional bodies update their continuing professional development rules to include AI courses. The obligation for members follows the new rules.

The decree allows six months from its entry into force (23 October 2026): the date is calculated.

Who it applies to: National councils of professional bodies; then their registered members.

AI Act: general-purpose AI models placed on the market before 2 August 2025

General-purpose AI models placed on the market before 2 August 2025 must comply with the obligations in Chapter V (technical documentation, information for downstream providers, copyright policy, summary of training content) by 2 August 2027.

Who it applies to: Providers of general-purpose AI models.

AI Act: high-risk systems in Annex III

For high-risk systems in Annex III, the classification rules, the requirements (risk management, data, technical documentation, record-keeping, transparency, human oversight, accuracy, robustness and cybersecurity) and the obligations of providers, importers, distributors and deployers apply. Systems already on the market or in service remain outside until their design undergoes significant changes. What counts is the type and model, not the individual unit: if a first unit was already on the market, later identical units follow the same rule (Article 111(2)). For those intended for use by public authorities the final deadline is 2 August 2030.

Postponed by Regulation (EU) 2026/1744: it was previously 2 August 2026.

Who it applies to: Providers, authorised representatives, importers, distributors and deployers of Annex III systems, including public bodies.

AI Act: high-risk systems in Annex I (regulated products)

For AI systems that are products, or safety components of products, covered by the legislation in Annex I (for example toys, lifts, radio equipment, medical devices), the high-risk requirements and obligations apply. The date was postponed by Regulation 2026/1744: it was previously 2 August 2027. Systems already on the market or in service remain outside until their design undergoes significant changes. What counts is the type and model, not the individual unit: if a first unit was already on the market, later identical units follow the same rule (Article 111(2)).

Proposal COM(2025) 1023 is pending: it would move medical devices and in vitro diagnostic medical devices to Section B of Annex I, taking them out of this deadline. Until it is adopted, the current date and scope apply. The procedure

Who it applies to: Manufacturers and providers of products in Annex I, Section A; deployers.

Machinery with AI: requirements in the Machinery Regulation

With machinery leaving Section A of Annex I to the AI Act, the requirements for high-risk AI in machinery will become new essential requirements of Machinery Regulation (EU) 2023/1230, through delegated acts to apply by 2 August 2028 at the latest.

It depends on Commission delegated acts not yet adopted: the actual date will be the one they set.

Who it applies to: Manufacturers of machinery with high-risk AI systems as safety components.

AI Act: high-risk systems already on the market intended for use by public authorities

High-risk systems already on the market or in service and intended for use by public authorities must be brought into compliance by this date, even without changes. New systems follow 2 December 2027 or 2 August 2028.

Who it applies to: Providers and deployers of high-risk systems intended for use by public authorities.