When does the EU AI Act start being enforced? The answer will vary depending on what type of AI we are talking about.
As we are getting closer to the plenary vote on the EU AI Act, provisionally scheduled for April 10-11, there is some confusion as to when the law actually comes into effect.
After the European Parliament vote, and assuming it goes through as expected, the new legislation will need to be entered into the EUR-Lex Official Journal of the European Union. The law comes into force 20 days after this event.
Even though it comes into force, the legislation first enters into what is called "Vacatio legis". This is a transitional period intended to give stakeholders time to adapt and make any necessary changes to their tools and operations before legislation is applied.
The deadline for Vacatio legis varies for different applications:
◦ The parts concerning prohibited AI systems apply after 6 months. I would expect as early as December.
◦ Specific obligations for "general-purpose" systems come into effect after 12 months. Therefore, around mid-2025 is something that "foundation models" and "AI assistants" likely need to consider.
◦ In essence, the rest of the act comes into effect after 24 months, presumably around mid-2026 - this is what most people have in mind when they say that the AI Act becomes operational after 2 years.
◦ However, there are also details that only come into effect after 36 months, and these are related to the parts in Annex II.
I made this timeline to give you a very quick and brief overview of these next steps before the AI Act comes into full enforcement. References for further reading are provided in my blog post on axbom.com