On August 1, the European Union's Artificial Intelligence Act (Act) entered into force. This groundbreaking legislation is set to be implemented in stages over the coming years and is expected to have a profound impact on the use and development of artificial intelligence (AI) systems both within the European Union and globally. Once in full effect, the Act will be the world's first comprehensive set of regulations governing AI.
Key dates and corresponding implementations are as follows:
- August 1, 2024: The Act went into force.
- February 1, 2025: Prohibitions against AI systems that pose unacceptable risks come into effect. Examples include systems used for cognitive behavioral manipulation of specific vulnerable groups, social scoring, and biometric categorization.
- May 1, 2025: Codes of practice (yet to be published) apply to developers of in-scope AI applications.
- August 1, 2025: Transparency requirements for general-purpose AI (GPAI) models come into effect. Providers of GPAI models must, among other obligations, disclose whether content was generated by AI, design their GPAI models in a manner that prevents the models from generating illegal content, and publish summaries of the copyrighted data used to train their GPAI models. GPAI models already on the market as of August 1, 2025, such as OpenAI's GPT-4, will have an additional 24 months to comply with these requirements.
- August 1, 2026: Requirements for most high-risk AI systems come into effect. Transparency requirements for AI systems classified as limited-risk also come into effect.
- August 1, 2027: GPAI models on the market as of August 1, 2025, must fully comply with the Act's requirements. Furthermore, the requirements for high-risk AI systems subject to European Union harmonization legislation also come into effect.
For more information on the Act, see here for our more in-depth analysis.
We will continue to monitor the Act's implementation, as well as any additional guidance and codes of practice that the European Commission may issue over the coming months. If you have any questions regarding the Act, how it may impact your business, or the best ways to prepare for its implementation, please contact the authors.
The authors wish to thank Bass, Berry & Sims summer associate Alessandro Colangelo for his contributions to this alert.
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