EU AI Act (Regulation (EU) 2024/1689)

Dates changed in 2026

The AI Act (Regulation (EU) 2024/1689) was amended by Regulation (EU) 2026/1744, often called the Digital Omnibus on AI, which enters into force on the third day following its publication in the Official Journal. EUR-Lex’s consolidated text of the AI Act is dated 27 July 2026.

As amended, the high-risk requirements in Chapter III, Sections 1, 2 and 3 apply from 2 December 2027 for systems classified as high-risk under Article 6(2) and Annex III, and from 2 August 2028 for systems classified under Article 6(1) and Annex I. The Omnibus’s recitals explain the postponement by the delayed availability of standards, common specifications and guidance, and the delayed establishment of national competent authorities.

Article 113(b) is not postponed with those high-risk dates: Chapter V shall apply from 2 August 2025. Chapter V is about providers of general-purpose AI models, not high-risk systems. See EU AI Act general-purpose AI model obligations.

Planning documents written before July 2026 will usually show 2 August 2026 and 2 August 2027 for high-risk Chapter III. Use the amended dates.

Military and defense exclusion

Article 2(3) says the Regulation does not apply to AI systems where and in so far they are placed on the market, put into service, or used with or without modification exclusively for military, defence or national security purposes, regardless of the type of entity carrying out those activities.

The exclusion is use-based. Recital 24 states that if such a system is used for civilian, humanitarian, law enforcement or public security purposes, it falls within the Regulation, and that a system placed on the market for both an excluded and a non-excluded purpose falls within the scope. Dual-use aerospace suppliers should read the recital closely.

Civil aviation

Civil aviation is handled through the sectoral regime rather than directly. Annex I, Section B lists Regulation (EU) 2018/1139 on civil aviation, in so far as it concerns unmanned aircraft and their engines, propellers, parts and equipment to control them remotely. For high-risk systems linked to Section B legislation, only Article 6(1), Article 60a and Articles 102 to 112 apply.

Article 108 amends the EASA Basic Regulation so that, when adopting implementing and delegated acts on AI systems that are safety components, the requirements set out in Chapter III, Section 2 of the AI Act shall be taken into account. Our reading, not an official statement: for aviation, EASA’s rulemaking rather than the AI Act’s own conformity process looks like the channel through which AI requirements will arrive. See the EASA concept paper page, EU AI Act scope for defense and aviation, and EU AI Act obligations for aerospace suppliers outside the EU.

Documentation and logging for high-risk systems

Two provisions matter for audit evidence. Article 11 requires technical documentation drawn up before the system is placed on the market and kept up to date, containing at a minimum the elements in Annex IV. Article 12 requires that high-risk systems technically allow for the automatic recording of events (logs) over the lifetime of the system. Under Article 18, providers keep documentation at the disposal of authorities for a period ending 10 years after the system is placed on the market or put into service.

Not covered here

This page is a scoping guide, not a compliance analysis. General-purpose AI model obligations are on EU AI Act general-purpose AI model obligations. This explainer still does not cover prohibited practices or penalties. Read the consolidated text on EUR-Lex and take legal advice for your situation.