A role-based and risk-sensitive review
The AI Act framework distinguishes actors and categories of use rather than treating every software tool identically. Identify whether the organisation develops, places on the market, imports, distributes or deploys an AI system, and assess the relevant use case. Privacy, consumer, intellectual-property and sector rules can apply alongside AI obligations.
Check the current implementation timetable
The Commission reports that the Digital Omnibus entered into force on 27 July 2026. Its published timetable places the main high-risk-system obligations at 2 December 2027, with high-risk AI embedded in regulated products at 2 August 2028; other provisions have earlier or distinct dates. This guide is dated 1 November 2026. Use the current official timeline for the particular obligation rather than relying on the original Act’s headline dates. A governance plan should record system classification, responsible roles, oversight, supplier commitments and evidence of the applicable phase.
Practical questions to resolve
- Inventory systems, uses and organisational roles
- Check the current rule-specific implementation date
- Document classification, governance and supplier responsibilities
Primary sources & further reading
Connect the framework to local law
The instrument is one part of the analysis. The countries, facts, relevant dates, national procedure and authority to act determine how it can be used in a particular matter.
These guides provide general legal information. The operative law, deadlines, professional permissions and scope of work are confirmed for the particular matter. Representation is arranged through appropriately authorised local practitioners.