Article 111(2) sets a grace period for high-risk systems placed on the market before a given date. The Digital Omnibus rewrote the paragraph and removed the date: it now refers to Article 113, which gives two different dates depending on the annex.
If your company is in the EU and uses AI in its operations, the answer is yes — and none of the article's exclusions change that. It's worth knowing what they are, because three of them are almost always cited wrong.
2 August 2026: the AI Act's transparency obligations move from a date on a calendar to a rule in application. What exactly changes that day, for whom — and why, for those who did their homework in July, entry into application demands nothing special.
Fear sells better than precision, so it's worth saying what the Regulation does not provide for. There is no automatic fine, no registration duty for a private company, and the high-risk regime does not apply yet.
Almost all of your AI risk enters through the vendor door. These ten questions — before signing, and at every renewal — separate serious vendors from the ones with just a pretty landing page. And an evasive answer is information too.
Admission, learning outcomes, level guidance — and exam monitoring. Point 3 of Annex III covers almost the whole student cycle, including one tool most schools don't think of as AI.
Not a year-long project, not an afternoon checklist: a well-sequenced month leaves an SME with an inventory, a classification, a policy, recorded training and its first transparency evidence. Week by week, this is what can genuinely be done.
In almost any company, the high-risk system is the one HR uses. In a recruitment agency, HR and the business are the same thing — and the people being evaluated are not its own workers, which changes who has to be informed.
2 August doesn't just activate obligations: it starts up the machinery that can ask about them. What a market surveillance action is, what documentation it will request, and why the enforcement powers coming into play shouldn't cost you any sleep — if your file is in order.
The Article 50 transparency obligations apply from 2 August 2026. A company that already has its inventory up to date can close the gaps in little time: here's what to check — and what not to.