Ready or Not, Here Comes the EU AI Act

We have been writing about the EU AI Act (the “Act”) for several months, and it is now here. On August 1, the EU AI Act went into effect. Now the countdown begins for the effective dates of various provisions of the Act.

Provision Effective Dates

• February 1, 2025: Enforcement of prohibitions on unacceptable risk AI.
• August 2, 2025: Obligations go into effect for providers of general purpose AI models.
• February 2, 2026: The EU Commission implements Act on post-market monitoring.
• August 2, 2026: Obligations go into effect for high risk AI systems, specifically listed in the Act (Annex III), including systems in biometrics, critical infrastructure, education, employment, access to essential public services, law enforcement, immigration, and administration of justice.
• August 2, 2027: Obligations go into effect for high risk AI systems that are not prescribed in Annex III of the Act, but are intended to be used as a safety component of a product. Obligations also go into effect for high risk AI systems in which the AI itself is a product and the product is required to undergo a third-party conformity assessment. Examples are toys, radio equipment, in vitro diagnostic medical devices, civil aviation security, and agricultural vehicles.
• End of 2030: Obligations go into effect for AI systems that are components of the large scale information technology systems established by EU Law in the areas of freedom, security, and justice.

We can also expect a series of guidance documents to be issued by the EU Commission to further assist companies in complying with the Act.

Closing

To read more about the Act, check out our previous blog posts and podcast on the subject below:

• April 1, 2024: PrivacyCafé – Analysis & Implications of the EU AI Act 
• March 20, 2024: A Closer Look: EU’s Finalized AI Act & What It Means for the U.S. 
• March 6, 2024: Compromise Brings EU Artificial Intelligence Act One Step Closer to Final 
• February 6, 2024: Forecasting 2024 Global Privacy Legislative Developments 
• January 16, 2024: The World’s First Comprehensive AI Law — the EU AI Act — is a Landmark in AI Regulation 
• December 5, 2023: EU-UK Data Privacy Round Up 

If you have questions about these provisions, please reach out to our Data Privacy & Cybersecurity team at Hall Booth Smith.

Disclaimer

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