The amended timeline significantly delays major compliance obligations. High-risk AI systems in certain uses now face a December 2, 2027 deadline instead of August 2026. AI systems classified as products or safety components under product-safety rules move to August 2, 2028. Transparency rules for AI-generated and manipulated content remain due in August 2026, though existing generative AI systems receive a shorter deferral until December 2, 2026. The full text of the agreement has not yet been published.
Companies preparing for the original August 2026 deadlines—particularly employers using AI for hiring, biometrics vendors, critical infrastructure operators, and product manufacturers—should reassess their compliance timelines. The new prohibitions on intimate image generation represent a substantive expansion of the Act's scope. With the Commission already issuing guidance and draft codes of practice on transparency obligations, implementation is moving into a more concrete phase. Counsel should monitor the formal legislative adoption process and any implementing guidance from EU authorities.