Article 113 — Entry into force and application (EU AI Act)

Article 113 of Regulation (EU) 2024/1689 — Entry into force and application. Official text, practical interpretation, key obligations and compliance implications.

Official Text Summary

Article 113 of Regulation (EU) 2024/1689 — the EU AI Act — establishes the date on which the Regulation entered into force and the phased schedule by which its individual provisions become applicable. The Regulation entered into force on the twentieth day following its publication in the Official Journal of the European Union, which occurred on 12 July 2024, placing the entry-into-force date at 1 August 2024.

The article then lays out a differentiated application timetable. The Regulation applies in full from 2 August 2026, which is two years after the entry-into-force date. However, several clusters of provisions apply earlier. Chapter I (general provisions) and Chapter II (prohibited AI practices) became applicable six months after entry into force, on 2 February 2025. Chapter V (general-purpose AI models), Chapter VII (governance), Chapter XII (penalties), and certain other provisions apply twelve months after entry into force, from 2 August 2025. Provisions relating to high-risk AI systems listed in Annex I — those embedded in products already subject to Union harmonisation legislation — apply from 2 August 2027, giving that sector a three-year adaptation window from the entry-into-force date.

This staggered structure reflects the legislature's intent to prioritise the elimination of the most serious risks first, while granting industry and national authorities adequate time to build compliance infrastructure for the more technically complex obligations.

What This Means in Practice

For organisations developing, deploying, or using AI systems within the scope of Regulation 2024/1689, Article 113 defines the operative compliance calendar against which all internal readiness programmes must be benchmarked.

Providers and deployers of prohibited AI systems — such as social scoring systems or real-time remote biometric identification in public spaces — had no grace period beyond 2 February 2025. Any system in one of the prohibited categories that remained in use after that date exposed the operator to enforcement action under the Regulation's penalties framework.

Providers of general-purpose AI models, including frontier models with systemic risk, faced the next hard deadline: 2 August 2025. From that date, GPAI model providers must maintain technical documentation, comply with copyright transparency requirements, and — where systemic risk is identified — conduct adversarial testing and incident reporting obligations.

For providers of high-risk AI systems falling under Annex III categories (employment, education, essential services, law enforcement, migration, and administration of justice), the full conformity assessment, technical documentation, and post-market monitoring obligations apply from 2 August 2026. Organisations should have completed gap analyses, appointed EU-authorised representatives where required, and registered systems in the EU database well before that date.

Manufacturers placing high-risk AI as a safety component into products regulated by Annex I legislation (machinery, medical devices, civil aviation equipment) have until 2 August 2027, but should not treat this extended window as an invitation to delay, given the lead time required for notified-body conformity assessments.

Key Obligations

• Immediate effect from 1 August 2024: The Regulation is legally binding across all EU Member States from the entry-into-force date; no national transposition is required.
• Prohibited practices ban from 2 February 2025: Chapter II prohibitions are directly enforceable; organisations must have removed or ceased operating any prohibited AI system by this date.
• GPAI compliance from 2 August 2025: Providers of general-purpose AI models must meet transparency, documentation, and systemic-risk obligations under Chapter V from this date.
• Full Regulation application from 2 August 2026: All remaining obligations — including high-risk system requirements under Annex III — become enforceable; this is the primary compliance deadline for most market actors.
• Annex I high-risk systems deadline of 2 August 2027: Providers of AI safety components embedded in products governed by existing Union harmonisation legislation have an additional year to achieve compliance.
• Governance and AI Office provisions from August 2024/2025: National competent authorities and the AI Office at EU level are operational and exercising supervisory functions throughout the phased application period.

Relationship to Other Articles

Article 113 must be read alongside Article 111 (transitional provisions), which governs the treatment of AI systems already on the market before 2 August 2026, and Article 112 (delegated acts), which grants the Commission authority to update certain Annexes during the application period. The phased timetable in Article 113 directly activates the substantive obligations set out in Chapter II (prohibited practices, Article 5), Chapter V (general-purpose AI models, Articles 51–56), Chapter VI (measures supporting innovation, Articles 57–63), and Chapter VII (governance, Articles 64–70). Penalties under Article 99 and Article 101 only become enforceable as each cluster of provisions reaches its application date, meaning Article 113 effectively regulates the chronological scope of the enforcement powers conferred throughout the Regulation. National market surveillance authorities deriving their mandate from Article 74 began exercising jurisdiction progressively in line with the same schedule.

Compliance Timeline

Organisations should treat 2 August 2026 as the primary compliance deadline driving internal project plans, with interim milestones at February 2025 and August 2025 already passed. As of mid-2026, the window for completing conformity assessments, technical documentation, and EU database registration for Annex III high-risk systems is narrow. For Annex I embedded systems, the 2027 deadline remains active but notified-body capacity constraints make early engagement essential.