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AI Act 2026: what companies need to implement now

AI literacy, transparency obligations, prohibitions and high-risk systems: which EU AI Act duties apply in 2026 and what companies should actually do.

Compliance3 min readBy AI München

Key points
  • Since February 2025: AI literacy (Art. 4) and prohibitions (Art. 5).
  • Since 2 August 2026: transparency obligations, e.g. for chatbots (Art. 50).
  • High-risk obligations under Annex III: postponed to December 2027 by the digital omnibus.

The EU AI Act applies in stages, and in 2026 it affects almost every company that uses AI. The key obligations today: your staff need sufficient AI literacy, prohibited AI practices are off-limits, and since 2 August 2026 chatbots must identify themselves as AI. The strict rules for high-risk systems come later, but should be planned for now.

What has applied since February 2025

Since 2 February 2025, certain AI practices have been prohibited, such as manipulative systems that exploit people's vulnerabilities, or social scoring. At the same time, Art. 4 requires providers and deployers of AI systems to take measures to ensure sufficient AI literacy among their staff. This also applies to a company that only uses AI tools such as chatbots or writing assistants.

What has applied since 2 August 2026

Since 2 August 2026, the transparency obligations of Art. 50 apply. Particularly relevant for companies:

  • Chatbots and other AI systems that interact directly with people must be designed so people can tell they are interacting with AI, unless that is obvious.
  • Deepfakes must be disclosed as artificially generated.
  • AI-generated text published to inform the public on matters of public interest must be labelled, unless a person has reviewed it editorially and bears responsibility.

For machine-readable marking of AI-generated content by the providers of such systems, the digital omnibus sets 2 December 2026.

High-risk systems: later, but not forgotten

AI systems in sensitive areas such as recruitment, credit scoring or critical infrastructure are considered high-risk. The obligations for the high-risk systems in Annex III have been postponed by the digital omnibus to 2 December 2027. If you already use AI in recruitment, for example, start now with documentation, risk assessment and human oversight.

Checklist for your company

  1. Inventory: which AI systems and tools are used in the company, including unofficially?
  2. Classification: is a system prohibited, high-risk, subject to transparency rules or low-risk?
  3. Training: ensure role-based AI literacy and document participation.
  4. Policy: define which tools may be used for what, and how data is handled.
  5. Transparency: label chatbots and check which publications need a label.
  6. Accountability: appoint a person responsible for AI in the company.
Tip: The AI Act does not replace the GDPR. Almost every AI project is subject to both: the AI Act for the system, the GDPR for the personal data.

We support you with AI training and AI Act compliance and set up AI chatbots with the required disclosure. Request the free AI Scan.

This article is general information and not legal advice.

Frequently asked questions

Does the AI Act apply to companies that only use AI tools?

Yes. Anyone using AI systems professionally is a deployer under the AI Act and must, among other things, ensure sufficient AI literacy among staff.

Does my website chatbot have to be labelled as AI?

Yes. Since 2 August 2026, people must be able to tell they are interacting with an AI system, unless that is obvious.

When do the high-risk AI obligations apply?

For the high-risk systems in Annex III, the obligations have been postponed by the digital omnibus to 2 December 2027.

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