Fixed law is what has been enacted and published: Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, with the application dates in the amended Article 113. Expected change is everything else in the pipeline: further simplification proposals, harmonised standards that have not yet been cited, Commission guidance and codes of practice that have not yet been finalised, and national implementation measures that are still being prepared. A planning record should label each item FIXED or EXPECTED, name its source and date, and never file an expected item as if it were already law.
Why must fixed and expected change be kept apart?
Fixed and expected change must be kept apart because they support different kinds of decision. Fixed law can support a release, a contract term or a conformity route, subject to checking the consolidated text. Expected change can only support a watch item, a scenario or a preparation task, and treating it as fixed can lead a team to build to a proposal that is later amended, delayed or abandoned. The AI Act pipeline makes the distinction especially important: the Act relies on harmonised standards, Commission guidance, codes of practice and national measures that arrive on different timetables from the Regulation itself. A single undated claim such as a standard being ready or a proposal being agreed therefore hides the most important fact about it, which is its status. Labelling status at the point of capture is cheaper than reconstructing it later, when a decision is being audited.
What is fixed in law now?
The fixed position is the consolidated Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, which entered into force on 27 July 2026. Its amended Article 113 sets the application dates that planning should use: prohibitions and literacy from 2 February 2025, general-purpose AI rules from 2 August 2025, most remaining rules including Article 50 from 2 August 2026, new prohibitions and the Article 50(2) transition end on 2 December 2026, Annex III high-risk rules from 2 December 2027 and Annex I product rules from 2 August 2028. Article 111 transitions, including the 2 August 2027 date for older general-purpose AI models and the 31 December 2030 date for Annex X large-scale IT system components, are also fixed text. Any claim that contradicts those dates should be treated as superseded unless it cites a later enacted amendment, and the consolidated text should be checked before the claim is repeated.
For the broader regulatory framework, see EU AI Act timeline.
What is in the standards pipeline?
Harmonised standards are a central part of the high-risk framework because they can give a presumption of conformity where the Act provides for it, but a standard only has that effect when it has been developed, cited in the Official Journal and applied within its stated scope. Until then, a draft standard, a standardisation request or a published standard that has not been cited should be labelled EXPECTED and described by its stage, not as a compliance route already available. Teams should record the standardisation body, the subject, the stage reached and the date checked, and should not assert current counts of published or cited standards without a primary source dated at the time of checking. Where a standard is relevant to a system, the preparation task is to track its progress and test the design against its draft requirements, while keeping the legal requirements in the Act itself as the fixed baseline for the conformity record.
What is in the guidance and codes pipeline?
Commission guidance, AI Office guidance, guidelines on scope and classification, and codes of practice for general-purpose AI models are important implementation material, but they are not the Regulation and their status varies by document. A code of practice or guideline that is final and published should be cited with its date and issuing body; a draft under consultation should be labelled as a draft and dated; a proposal for future guidance should be recorded only as a watch item. The same discipline applies to national measures: Member States designate authorities, adopt penalty rules and establish sandboxes on their own timetables, so a claim about a national position should name the Member State and the measure. Where guidance interprets a provision, the record should keep the guidance and the legal text side by side, so a later change to either one can be traced to the decisions that relied on it.
How should a team maintain a dated source of truth?
A dated source of truth is a single record, per system and per provision, that carries the provision, the application date, the transition if any, the official source consulted and the date last checked. It should distinguish the consolidated legal text from guidance, standards and secondary commentary, and it should carry a review trigger for each entry: a fixed milestone, a guidance publication, a standards citation or a change to the system. When a source changes, the entry should be updated with what changed, which systems were reassessed and who approved the update, preserving the earlier position rather than overwriting it silently. That history matters because a classification or conformity decision may later need to show what was known at the time it was made. A source of truth without dates, or with only secondary sources, cannot do that work and should not be relied on for a release decision.
Continue with what Regulation (EU) 2026/1744 changed.
What does this guide not decide?
This guide does not predict whether any proposal will be enacted, when any standard will be cited or what any future guidance will say, and it does not assign a readiness status to any standard, notified body or national measure. Those are matters for the primary source concerned, checked on the date of reliance, and this guide deliberately gives no counts, no readiness ratings and no expected dates for pipeline items that have not been verified. It also does not decide how a future change would affect a specific system, since that depends on the enacted text and the system's purpose and design at the time. Where a plan depends on expected change, label it as a scenario, keep the fixed-law baseline intact, and confirm the position with a competent authority or legal adviser before committing to a release or contract on the strength of it.
Frequently asked questions
Is a draft standard enough to claim conformity?
No. A draft or uncited standard should be treated as pipeline material, labelled EXPECTED with its stage and date. A presumption of conformity depends on the conditions in the Act and on citation, which should be checked in the current official text.
Does Commission guidance change the law?
No. Guidance interprets and supports the Regulation but does not replace it. A record should keep the guidance and the consolidated legal text side by side, each cited with its date and issuing body.
Should further simplification proposals be planned as law?
No. Any proposal beyond Regulation (EU) 2026/1744 is expected only until enacted text is verified in the Official Journal. It should be recorded as a watch item or scenario, not as a fixed date or duty.
Continue through this AI Act cluster
This article is an informational overview, not a legal determination. Check the current legal text and official implementation guidance for your system and role.
Consolidated Regulation (EU) 2024/1689, as amended ↗AI Act Service Desk implementation timeline ↗