EU AI Act — Legacy GPAI & Embedded High-Risk Compliance

What this countdown tracks

On 2 August 2027, the AI Act's final major compliance wave lands: GPAI models placed on the market before 2 August 2025 must be brought into full compliance, and high-risk AI systems embedded in products already regulated under EU product-safety legislation fall within scope. This countdown marks the end of the transitional grace period for legacy systems.

Background

Article 111 of Regulation (EU) 2024/1689 grants providers of GPAI models placed on the market before 2 August 2025 a two-year window to align with the Act's obligations — documentation, copyright policy, training-data summaries, and, where applicable, systemic-risk duties. That window closes on 2 August 2027. Separately, Article 6(1) high-risk systems — AI used as a safety component of products covered by harmonisation legislation listed in Annex I (machinery, toys, lifts, medical devices, in-vitro diagnostics, civil aviation, motor vehicles, rail, marine equipment) — only become subject to the high-risk regime from that same date.

The effect is substantial. Models such as those released in 2023 and early 2024, which have been operating under lighter voluntary commitments, must complete full conformity work: Annex XI and XII technical documentation, systemic-risk evaluations where the 10^25 FLOP threshold is crossed, adversarial-testing records, and serious-incident reporting pipelines. For product manufacturers, AI components embedded in regulated hardware must pass through notified-body conformity assessment alongside existing CE-marking routes, adding a new testing and certification layer. The Commission has indicated that between 85 and 90 per cent of high-risk AI systems placed on the EU market are expected to fall under Article 6(1) rather than Article 6(2), meaning this phase covers the bulk of the regulated population. Notified-body accreditations for AI conformity are being rolled out through 2026–2027 by national accreditation authorities, with capacity concerns flagged by MedTech Europe and the European Automobile Manufacturers' Association in their Article 111 consultation responses.

Why the date matters

2 August 2027 closes a deliberate transition corridor. It gives providers and manufacturers three years from entry-into-force to align legacy systems, and it synchronises AI-specific conformity with product-safety cycles so manufacturers can bundle assessments. After that date, regulators can treat non-compliant legacy models and embedded systems on the same footing as new entrants, enabling withdrawal orders, recalls, and fines. It is also the date from which importers and distributors become liable for placing non-compliant AI-embedded products on the EU market, tightening due-diligence obligations along the full supply chain.

What to watch for

• Status reports from large pre-2025 GPAI providers on compliance gaps.
• Notified-body capacity for AI conformity in medical-device and automotive sectors.
• Commission guidance on "significant modification" triggers that reset compliance.
• Member-state enforcement postures on legacy open-source model distributions.
• Coordination between AI Office and sectoral regulators such as EMA and EASA.
• Volume of Annex XI technical files actually filed by the deadline.
• Market withdrawals of non-compliant AI-enabled products.

Related events to track

This phase follows the main EU AI Act enforcement countdown one year earlier. Cross-regime dynamics link to the DMA first review countdown, which may widen DMA scope to AI systems, and the GDPR 10-year review countdown, which bears on AI training-data lawfulness.

FAQ

When exactly is EU AI Act Phase 2? 2 August 2027, the date set by Article 111 for legacy GPAI and Article 6(1) Annex-I embedded high-risk systems.

Is EU AI Act Phase 2 confirmed or expected? Confirmed by the published text of Regulation (EU) 2024/1689.

Who is responsible for EU AI Act Phase 2 enforcement? The European AI Office for GPAI; national market surveillance authorities and notified bodies for embedded high-risk systems.

Where can I read the official announcement? Implementation dates are documented at https://artificialintelligenceact.eu/implementation-timeline/.