In short. GPAI obligations apply from 2 August 2025, enforcement powers from 2 August 2026, and models placed on the market before 2 August 2025 must comply by 2 August 2027.
Definition: The AI Act application timeline is the phased schedule for applying the European Union's AI rules. It separates the start of model-provider obligations, the start of enforcement powers and the compliance deadline for models already on the market.
Key facts
- As of 17 October 2026, the Commission's provider FAQ describes general-purpose AI (GPAI) models as supporting various tasks and integration into downstream AI systems.
- The Commission's consolidated Article 113 text sets general application at 2 August 2026, with Chapter V on GPAI models applying from 2 August 2025.
- The Commission's application and enforcement guidance places the start of its GPAI enforcement powers, including fines, at 2 August 2026.
- Article 111(3) gives providers of GPAI models placed on the market before 2 August 2025 until 2 August 2027 to comply.
Which date determines a model provider's deadline?
The relevant event is the model's first availability on the Union market. The Commission's provider FAQ includes access through application programming interfaces (APIs), downloads, cloud services and integration into applications. A provider develops a model, or has it developed, and places it on the market under its own name or trademark; this includes providers established outside the EU.
The Commission's implementation guidance states that providers placing GPAI models on the market from the August 2025 start must comply with the applicable obligations. For earlier models, Article 111(3) supplies the later compliance deadline. Model providers therefore need the market-placement date alongside the applicable legal provision.
The Commission's Article 113 reproduction, based on the consolidated text of 27 July 2026, supplies these legal references for Regulation (EU) 2024/1689:
Article 113, third paragraph, point (b): Chapter V applies from 2 August 2025.
Article 101: excluded from that early start; applies from 2 August 2026.
Article 111(3): pre-2 August 2025 models must comply by 2 August 2027.
The final line follows the separate existing-model provision.
What obligations matter for website content?
The model deadline covers duties relevant to content used in training. Article 53(1)(c) and (d) require a policy for compliance with Union copyright law, including identifying and respecting rights reservations, and a sufficiently detailed public summary of training content using the AI Office's template.
The same article requires technical documentation for authorities and information for providers integrating the model into AI systems. Its conditional exemption for certain free and open-source models concerns those documentation duties; the copyright-policy and public-summary duties continue to apply. For a website publisher examining a provider's training summary, the model's market-placement date determines whether the existing-model transition is relevant.
How do the other application dates fit?
The Commission's implementation FAQ dates the application of definitions and AI-literacy provisions to 2 February 2025. It also records the Digital Omnibus entering into force on 27 July 2026 and extending high-risk system deadlines.
The consolidated Article 113 assigns 2 December 2027 to the specified high-risk requirements for systems classified under Article 6(2) and Annex III, and 2 August 2028 for those classified under Article 6(1) and Annex I. Those dates concern high-risk AI systems. The GPAI model-provider dates remain a separate part of the timetable.
Related terms
- General-purpose AI model under the AI Act
- AI Act Article 53
- AI Act training content summary
- General-Purpose AI Code of Practice
FAQ
Do GPAI obligations begin with enforcement in August 2026?
The Commission's guidance separates the August 2025 start of obligations from the August 2026 start of enforcement powers, including fines. The later enforcement date leaves the earlier application date in place.
Does an older model escape the provider obligations?
Article 111(3) gives providers of models placed on the market before 2 August 2025 a compliance deadline of 2 August 2027.
Are the Commission's provider guidelines legally binding?
The Commission's provider FAQ describes the guidelines as nonbinding and explains that they set out its interpretation for enforcement. An authoritative interpretation belongs to the Court of Justice of the European Union.
Sources
- European Commission, "Article 113: Entry into force and application", consolidated text as at 27 July 2026
- European Commission, "Guidelines on obligations for General-Purpose AI providers", undated
- European Commission, "Guidelines for providers of general-purpose AI models", updated 28 April 2026
- European Commission, "Article 111: AI systems already placed on the market or put into service and general-purpose AI models already placed on the marked", consolidated text as at 27 July 2026
- European Commission, "Article 53: Obligations for providers of general-purpose AI models", consolidated text as at 27 July 2026
- European Commission, "Navigating the AI Act", undated
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