25 April 2026
EU AI Act Infrastructure Requirements: Deadlines and Duties After the AI Omnibus
European AI teams face a critical regulatory shift. While the initial bans on prohibited practices took effect on 2 February 2025, 2 August 2026 is the date the Regulation applies in general and the date the Commission gains its power to fine general-purpose AI model providers under Article 101. The AI Omnibus, in force since 27 July 2026, then moved the Chapter III obligations for Annex III high-risk systems to 2 December 2027, and high-risk systems captured by Article 6(1), AI systems that are, or are safety components of, products covered by the EU product legislation listed in Annex I, to 2 August 2028. For teams building in sectors like healthcare, critical infrastructure, or employment, the Act requires evidence about the AI system and its operation. The necessary controls depend on the system and the provider's or deployer's role, rather than on a particular cloud architecture. Initial compliance work for a single high-risk system is a material cost line, and ongoing monitoring adds operational overhead on top of it. Moving beyond the 'move fast and break things' era, engineering teams must now treat compliance as a core component of their technical stack.
