You have lost track of the next steps, now that the AI Act has become law? Well, you are lucky - this regular updated blog post provides you with the key dates when it comes to the implementation and enforcement of the AI Act, focusing thereby on the upcoming 12 months.
The AI Act was published in the Official Journal of the EU on 12 July 2024. Twenty days later on 1 August 2024, the law entered into force and will become, in accordance with Article 113, applicable between 2 February 2025 and 2 August 2027, depending on the respective transition period. They key dates are:
• 24 January 2024: Commission decision to establish an EU AI Office. Communication on boosting startups and innovation in trustworthy AI. Proposal to amend the EuroHPC (Regulation (EU) 2021/1173) in order to set up AI Factories.
• 7 March 2024: Two calls for expression of interest to recruit new members, both technology specialists and administrative assistants, for the European AI Office.
• 16 April 2024: Special report of the European Court of Auditors that audits the European Commission's 'Coordinated plan on AI' from 2018 and 2021.
• 13 May 2024: Reply of the European Commission on the special report of the European Court of Auditors from 16 April 2024.
• 15 May 2024: Deadline for the nomination of the national representatives for the AI Board and the AI Committee (comitology).
• 30 May 2024: The AI Office run a webinar on risk management.
• 19 June 2024: The first high-level meeting of the upcoming AI Board took place in order to adopt the rules of procedure and to set up task-forces for specific questions related to the implementation of the AI Act.
• 16. July 2024: Statement of the EDPB on the role of Data Protection Authorities in the AI Act framework.
• 22 July 2024: The first draft version of the AI Pact was published.
• 30 July 2024: Call for expression of interest to participate in the drawing-up of the first GPAI Code of Practice. Launch of a multi-stakeholder consultation on trustworthy GPAI models under the AI Act.
• 10 September 2024: Meeting of the Working Party on 'Telecommunications and Information Society' in the Council of the EU on risk assessment methodology.
• 12 September 2024: Second meeting of the AI Board.
• 24 September 2024: Meeting of the Working Party on 'Telecommunications and Information Society' in the Council of the EU on the ECA report.
• October 2024: First meeting of the AI committee to start comitology for priority implementing acts (Article 98(2)).
• 02 November 2024: Deadline for Member States to notify the authorities that are responsible for fundamental rights protection (Article 77(2)).
• 02 February 2025: The prohibitions of Article 5 start to apply. Member States can decide to create a legal basis for the exceptional use of real-time remote biometric identification (RBI). In that case, they are obliged to notify the Commission within 30 days.
▶ The Commission will until present until that day: (a) an implementing act that revises the standardization mandate, (b) an implementing act that establishes the scientific panel of independent experts, (c) guidelines on the practical implementation of the AI system definition, and (d) guidelines on the practical implementation of the prohibitions, including reporting templates for Member States for use of real-time RBI.
• 02 May 2025: Finalization of the drafting of the code of practice for GPAI.
• 02 August 2025: The rules for GPAI models, governance and penalties start to apply.
▶ The Commission will present: (a) an implementing act on the modalities for the evaluation of GPAI models, (b) guidance about the reporting of serious incidents, (c) a report on the need to update the list of high-risk use cases and prohibited practices, and (d) a template for the sufficiently detailed summary of the content used for the training a GPAI models. The Commission is required by then to have completed the set-up of the scientific panel and the advisory forum.
▶ Member States need to designate at least two national competent authorities (market surveillance & notifying authority) and lay down the rules for penalties and other enforcement measures.
• 02 August 2026: Most parts of the AI Act become applicable.
• 02 August 2027: The sectorial sections of the AI Act, in particular Art 6(1) and Annex I, become applicable.
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