The Digital Omnibus's delay to high-risk-system requirements became law in July. Article 50 transparency obligations still begin August 2, when Commission enforcement powers over GPAI providers also enter into application.
GPAI obligations have applied since August 2, 2025, to models placed on the market after that date. Models already on the market before then have until August 2, 2027, to comply. From August 2, 2026, the Commission can enforce the applicable obligations with fines (European Commission).
| Rule | Applies | Enforcement |
|---|---|---|
| GPAI duties for models placed on the market after Aug 2, 2025 | Aug 2, 2025 | Commission powers apply Aug 2, 2026 |
| GPAI duties for models already on the market before Aug 2, 2025 | Aug 2, 2027 | Commission enforcement when duties apply |
| Article 50 transparency obligations | Aug 2, 2026 | Competent authorities under the AI Act |
| High-risk system requirements | Delayed | Later dates under the amended timetable |
The Commission has published guidance for GPAI providers describing the documentation and compliance framework.
Signing the GPAI Code of Practice can reduce administrative burden and provide greater legal certainty. Non-signatories must demonstrate compliance through other adequate means assessed by the Commission (European Commission).
The high-risk delay does not change the GPAI obligations already in force or the Article 50 rules beginning August 2. Compliance calendars need separate rows for model placement dates, transparency duties, and high-risk-system requirements.
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