Article 110 of Regulation (EU) 2024/1689 — Amendment to the Representative Actions Directive. Official text, practical interpretation, key obligations and compliance implications.
Article 110 is one sentence with long reach: it adds the AI Act to Annex I of Directive (EU) 2020/1828 — the list of laws whose breach can be pursued through consumer representative actions. AI compliance failures become collectively litigable.
Official Text Summary
Article 110 amends Directive (EU) 2020/1828 on representative actions for the protection of the collective interests of consumers by adding the AI Act to its Annex I — the catalogue of Union law provisions whose infringement can be pursued through representative actions. Qualified entities designated by the Member States, typically consumer organisations, may bring actions for injunctive measures and for redress on behalf of consumers harmed by infringements of the Regulation. For providers and deployers of consumer-facing AI, this quietly changes the risk calculus: regulatory fines are no longer the only downside scenario, because the same infringement can also fuel coordinated private litigation.
Key Obligations
- The AI Act joins Annex I of Directive (EU) 2020/1828 on representative actions for the protection of consumers' collective interests
- Qualified entities — consumer organisations designated by Member States — may seek injunctions and redress on behalf of groups of consumers harmed by infringements of the Act
- Practical effect: an AI Act breach that harms consumers at scale can produce one coordinated action rather than thousands of individual claims
Compliance Timeline
Applies from 2 August 2026; the 2026 Digital Omnibus deferred the substantive high-risk obligations (Annex III to 2 December 2027, Annex I to 2 August 2028) but did not move this provision.
Official AI Act Compliance Deadline Calendar
Updated · Sources: Regulation (EU) 2024/1689 and the 2026 Digital Omnibus on AI.
| Obligation | Applies to | Original date | New date | Status | Countdown | Legal basis |
|---|---|---|---|---|---|---|
| Prohibited Practices (Art. 5) | All providers and deployers | active | — | AI Act Art. 5 | ||
| GPAI Rules (Chapter 5) | GPAI model providers | active | — | AI Act Art. 51-56 | ||
| Commission Enforcement Powers over GPAI | GPAI model providers | active | — | AI Act Art. 88-94, 101 | ||
| Transparency Obligations (Art. 50) | Providers and deployers of chatbots, generative, emotion recognition systems | active | — | AI Act Art. 50 | ||
| New Art. 5 Prohibition (CSAM / non-consensual intimate imagery) | Providers and deployers of generative AI systems | active | — | AI Omnibus 2026 Art. 5 | ||
| AI-Generated Content Marking (pre-existing systems) | Providers of generative AI systems on the market before 2 Aug 2026 | active | — | AI Act Art. 50(2) — transitional | ||
| Regulatory Sandboxes | National competent authorities | deferred | — | AI Omnibus 2026 Art. 57 | ||
| High-risk AI — Annex III (standalone) | Providers of standalone Annex III systems | deferred | — | AI Omnibus 2026 Art. 6(2) | ||
| High-risk AI — Annex I (embedded) | AI embedded in Annex I regulated products | deferred | — | AI Omnibus 2026 Art. 6(1) |
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AI Act meets DORA and NIS2
Is your organisation subject to both the AI Act and DORA? The two regulations intersect on the operational resilience of financial AI systems. Our sister site regulation-dora.eu covers DORA in depth — including what the AI Act adds on top of an existing DORA programme.
The AI Act for financial institutions ↗ Explore regulation-dora.eu ↗Frequently Asked Questions
Consumer-facing ones at scale: a prohibited practice deployed in a consumer product, an undisclosed chatbot in violation of Article 50, or a high-risk system used on consumers without its Chapter III safeguards. The qualified entity sues once, on behalf of the affected class.
They stack. Article 99 fines are public enforcement; representative actions are private enforcement of the same rules — injunctions and redress for consumers. A single incident can produce both, which is why consumer-scale AI deserves the strictest compliance tier.
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