EU AI Act for US companies: the dates after the Digital Omnibus (Oct 2026)
Short answer: yes, a US company that places an AI system on the EU market or whose AI output is used in the EU is in scope. After the Digital Omnibus (Regulation (EU) 2026/1744, in force 27 July 2026): AI literacy and prohibited practices already apply; Article 50 transparency applies from 2 August 2026; standalone high-risk systems in Annex III (including hiring and worker management) apply from 2 December 2027.
Dates
| Obligation | Applies from |
|---|---|
| Prohibited practices, AI literacy (Art. 4) | 2 Feb 2025 |
| Article 50 transparency (chatbots, synthetic content) | 2 Aug 2026 (marking grace for pre-existing systems to 2 Dec 2026) |
| High-risk Annex III (e.g. recruitment, credit scoring) | 2 Dec 2027 |
| High-risk in regulated products (Annex I) | 2 Aug 2028 |
Checklist for a US team
- Inventory every AI system and where its users are.
- Classify: prohibited / high-risk (Annex III) / transparency / minimal.
- Chatbots and voice agents: tell users they are talking to AI.
- Hiring tools sold into the EU: plan for high-risk documentation, logging and human oversight by Dec 2027.
- Keep one register you can hand to an EU customer's procurement team.
Get it done this week
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Start the free register entry → or reply to any Unadhi email with "YES" for a free personalised gap note.
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