Does the EU AI Act Apply to Your Company?
Transparency obligations become enforceable on 2 August 2026 — and they reach far beyond model providers. Answer a few questions to see whether your SaaS company is affected, which obligations apply, and by when.
Does your company have a connection to the EU?
The AI Act applies far beyond EU borders — what matters is where your AI or its output is used.
AI Act Deadlines After the Digital Omnibus
The Digital Omnibus on AI (Regulation (EU) 2026/1744) redrew the AI Act's application dates. Here's the current, binding timeline.
Prohibitions and AI literacy obligation applicable
Obligations for general-purpose AI model providers applicable
Transparency obligations enforceable — chatbot disclosure, AI content marking, deep fake disclosure
End of content-marking grace period for AI systems placed on the market before 2 Aug 2026
High-risk obligations for standalone AI systems (Annex III)
High-risk obligations for AI embedded in regulated products (Annex I)
“Applicable” means enforceable by a regulator — EU legislation typically enters into force first and becomes applicable after a transition period.
EU AI Act Applicability — Frequently Asked Questions
Does the EU AI Act apply to companies outside the EU?
Yes. The AI Act applies to providers placing AI systems on the EU market regardless of where they are established, and to providers and deployers in third countries when the output produced by their AI system is used in the EU. A US or UK SaaS company with EU customers is typically in scope.
My product just wraps OpenAI or Anthropic models — am I still a provider?
Usually yes. If you offer AI features under your own name or trademark — a branded chatbot, generative features in your app — you are a provider of that AI system under the AI Act, even though the underlying model comes from a third party. The model vendor's compliance does not replace yours.
What becomes enforceable on 2 August 2026?
The Article 50 transparency obligations: chatbots must disclose that users are interacting with AI, AI-generated content must be marked machine-readably as AI-generated (with a grace period to 2 December 2026 for systems already on the market), and deployers must disclose deep fakes and inform people about emotion recognition or biometric categorisation.
We host or serve AI models for others — are we in scope?
Likely yes. Under the Commission's GPAI guidelines, a model is 'placed on the market' when it is first made available in the EU via an API, software library, or download. An inference platform serving models through its own API can therefore become the provider of the general-purpose AI model, with obligations applicable since 2 August 2025 — technical documentation, information for downstream providers, a copyright policy, and a training-data summary. Purely providing compute on behalf of the original model provider generally does not trigger provider status.
What did the Digital Omnibus change?
The Digital Omnibus on AI (Regulation (EU) 2026/1744, in force since 27 July 2026) postponed the high-risk obligations to 2 December 2027 for standalone Annex III systems and 2 August 2028 for AI embedded in regulated products. Transparency obligations stayed on 2 August 2026, and the prohibitions and AI literacy duty remain applicable.
What are the penalties for non-compliance?
Up to €35M or 7% of global annual revenue for prohibited practices, up to €15M or 3% for most other violations including high-risk and transparency obligations, and up to €7.5M or 1% for supplying incorrect information to authorities.
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