When do the EU AI Act high-risk rules apply after the Digital Omnibus?

Under Article 113(c) of the AI Act as amended by the Digital Omnibus on AI, the high-risk rules in Chapter III, Sections 1 to 3, apply from 2 December 2027 for AI systems that are high-risk under Article 6(2) and Annex III (for example recruitment or creditworthiness), and from 2 August 2028 for AI systems that are high-risk under Article 6(1) and Annex I (AI in regulated products).

What applies to a small business using AI right now?

Chapters I and II have applied since 2 February 2025, which covers AI literacy (Article 4) and the prohibited practices (Article 5). The Commission's AI Act Service Desk says national enforcement of the prohibitions and of the Article 50 transparency rules started on 2 August 2026. Article 4 was amended by the Digital Omnibus but still requires providers and deployers to take measures to support the AI literacy of their staff.

What changes on 2 December 2026?

Two things. New prohibitions on AI that generates or manipulates non-consensual intimate material and child sexual abuse material apply from 2 December 2026 (Article 113(a)). And providers of AI systems placed on the market before 2 August 2026 have until 2 December 2026 to meet the marking and detection obligation in Article 50(2), according to the AI Act Service Desk FAQ.

EU AI Act dates after the Digital Omnibus: one-page deadline sheet for small EU businesses (2 December 2026, 2 December 2027, 2 August 2028)

Updated 20 Oct 2026 · Disclosure: the EURO AI Register mentioned below is an Unadhi product with a free edition. This guide is for information only, not legal advice.

What you get: a finished EU AI Act deadline sheet you can paste into Google Sheets or Excel: every date that matters to a small business, what starts on that date, who it hits, a yes/no column for your business, the action to take, an owner and a done date. Plus a short "do this before 2 December 2026" list and a checklist. Every date is taken from Article 113 of the AI Act as consolidated after the Digital Omnibus (Regulation (EU) 2026/1744), as shown on the Commission's AI Act Service Desk.

The short version

Already in force for every business using AI: AI literacy (Article 4) and the banned practices (Article 5), since 2 February 2025. National enforcement of the bans and of the Article 50 transparency rules (chatbots, deepfakes, AI-generated text published to inform the public) started on 2 August 2026.
Next date: 2 December 2026. New bans on AI that generates non-consensual intimate images or child sexual abuse material, and the end of the grace period for providers of older generative AI systems to mark their output as AI-made.
High-risk rules moved. The Digital Omnibus pushed the high-risk rules to 2 December 2027 for Annex III uses (such as recruitment, staff management and creditworthiness) and to 2 August 2028 for AI built into regulated products under Annex I.

Every date, in order

Date	What starts	Who it hits	Source
1 Aug 2024	The AI Act enters into force (nothing applies yet)	Nobody directly	Art. 113; Service Desk FAQ
2 Feb 2025	Chapters I and II: definitions, AI literacy (Art. 4) and prohibited practices (Art. 5)	Every provider and deployer, including a business that only uses AI tools	Art. 113(a)
2 Aug 2025	Rules for general-purpose AI models (Chapter V), governance (Chapter VII), notified bodies (Chapter III Section 4) and penalties (Chapter XII)	Mainly AI model makers; Member States set their penalty rules	Art. 113(b)
2 Aug 2026	General date of application. Article 50 transparency rules apply, and enforcement of the bans, the transparency rules and the GPAI rules can start	Deployers who publish deepfakes or AI text to inform the public, or use emotion recognition; providers of chatbots and generative AI	Art. 113; Service Desk FAQ
2 Dec 2026	New bans in Art. 5(1)(ba) and (bb), 5(1a) and 5(1b) on non-consensual intimate material and child sexual abuse material; end of the Art. 50(2) marking grace period for systems placed on the market before 2 Aug 2026	Providers of generative AI; anyone offering image or video generation	Art. 113(a); Service Desk FAQ
2 Dec 2027	High-risk rules (Chapter III, Sections 1 to 3) for Annex III systems: deployer duties in Art. 26, fundamental rights impact assessment in Art. 27 where it applies	Businesses using AI for recruitment, staff decisions, credit scoring and the other Annex III uses	Art. 113(c)(i)
2 Aug 2028	High-risk rules for AI systems that are high-risk under Art. 6(1) and Annex I (safety components of regulated products such as machinery or medical devices)	Makers and users of AI in regulated products	Art. 113(c)(ii)

One change small businesses should know about: Article 4 was amended by the Digital Omnibus. It still says providers and deployers "shall take measures to support the development of AI literacy" of their staff, and it now adds that this "does not require providers or deployers to guarantee any specific level of AI literacy of any individual". The Commission and Member States must support SMEs in meeting it, and the Commission will publish practical examples.

The deadline sheet (copy and fill in)

EU AI Act deadline sheet · Business: [name] · Filled in by: [name, role] · Date: [dd/mm/yyyy] · Next review: [every 3 months, and whenever you add an AI tool]

No.	Date	Rule	Applies to us? (yes/no/check)	Why (which tool or use)	Action	Owner	Due	Evidence kept
1	2 Feb 2025	AI literacy (Art. 4)	yes	[staff use AI chat, AI writing and AI bookkeeping tools]	[short training plus a dated attendance record]	[name]	[now]	[AI literacy record]
2	2 Feb 2025	Prohibited practices (Art. 5)	[check]	[any emotion recognition at work? any social scoring?]	[run the Article 5 list against every AI tool]	[name]	[now]	[dated check]
3	2 Aug 2026	Transparency (Art. 50)	[yes]	[website chatbot; AI images in ads]	[check the chatbot says it is AI; label deepfakes]	[name]	[now]	[screenshots with date]
4	2 Dec 2026	New bans; Art. 50(2) marking grace ends	[no]	[we do not offer image generation to others]	[ask our image tool supplier how it marks output]	[name]	[30 Nov 2026]	[supplier reply]
5	2 Dec 2027	High-risk, Annex III (Art. 26, 27)	[check]	[CV screening add-on in our hiring tool]	[confirm with supplier if high-risk; plan oversight and logs]	[name]	[30 Jun 2027]	[role check, supplier answer]
6	2 Aug 2028	High-risk, Annex I products	[no]	[we make no regulated products]	[none; re-check if that changes]	[name]	[n/a]	[note]

The six rows above are made-up examples to show how to fill the sheet, not real businesses or legal conclusions.

Keep one row per rule, and add a row whenever a new AI tool or a new use turns a "no" into "check". The "Evidence kept" column is what shows you actually did the work: a dated record beats a policy nobody signed.

Do this before 2 December 2026

List every AI tool and every use of it (SME AI inventory template)
Run each tool against the banned practices, including the two new bans (Article 5 list)
Record the AI literacy training you have given, with dates and names (Article 4 guide)
Check that any chatbot on your site tells people it is AI, and that published AI images and AI news text are labelled (Article 50 chatbot checklist, AI content label sheet)
Ask your image or video generation supplier how it marks output as AI-made
Note which tools might be high-risk in December 2027, and which role you hold for each (Annex III check, role check sheet)

This sheet is a starting point, not a legal opinion or proof of compliance. Dates were checked against the consolidated Article 113 and the FAQ on the Commission's AI Act Service Desk (text as at 27 July 2026) on 20 October 2026. Transitional rules for AI systems already on the market (Article 111) and national penalty rules are not covered here; check the official source and your national authority before relying on a date. Spot an error in this guide? Write to mininglife7@gmail.com.

For accountants and tax advisers

Clients are hearing "the AI Act was postponed" and stopping work. Only the high-risk dates moved; AI literacy and the bans already apply, and transparency is now enforced. At your next client review, hand over this sheet next to the client AI inventory workshop and diarise the three dates: 2 December 2026, 2 December 2027 and 2 August 2028. Stay inside your professional rules and pass legal questions to a lawyer.

Keep the dates with your AI register

The EURO AI Register free edition runs in your browser with no account and no upload. It covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. List each AI tool once, pick its role, and store the date you checked each row of this sheet as an evidence record against that tool.

When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is legal advice or proof of compliance.

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Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.

Sources

European Commission AI Act Service Desk: Article 113, entry into force and application (consolidated text with Digital Omnibus amendments)
European Commission AI Act Service Desk: Article 4, AI literacy (as amended)
European Commission AI Act Service Desk: FAQ (enforcement from 2 August 2026; Article 50(2) grace to 2 December 2026; Annex III from 2 December 2027; Annex I from 2 August 2028)
Regulation (EU) 2024/1689 (AI Act): Articles 4, 5, 6, 26, 27, 50, 111 and 113, Annexes I and III
Regulation (EU) 2026/1744 (Digital Omnibus on AI), published 24 July 2026

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Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.