The August 2026 deadline applies to the Chapter 2 requirements (Articles 8–15) and the conformity assessment, registration, and CE marking obligations for Annex III high-risk systems. Annex I product systems benefit from an extended deadline of August 2027. Article 4 (AI literacy) and Article 5 (prohibited practices) already apply. GPAI obligations under Articles 51–56 apply from August 2025.

For brownfield compliance, the AI Governance Lead sets interim milestones. A reasonable schedule for a medium-complexity system: Phase A complete by Q4 2025 (critical controls operational), Phase B complete by Q1 2026 (AISDP substantially assembled), Phase C complete by Q2 2026 (infrastructure gaps closed), and formal conformity assessment conducted in Q2–Q3 2026 with the Declaration of Conformity signed before August 2026.

Organisations with large portfolios may not achieve full compliance for all systems by August 2026. In this case, the portfolio prioritisation framework determines which systems are addressed first, and the organisation documents its compliance programme’s scope and timeline for the remaining systems.

Key outputs

• Milestone schedule aligned with August 2026 deadline
• Phased A/B/C completion targets by quarter
• Portfolio prioritisation for organisations with large portfolios
• Compliance programme documentation for systems beyond the deadline