EU AI Act Timeline: Key Dates from 2025 to 2028

The EU AI Act (AI Act) enters into force gradually: the first obligations began on 2 February 2025, general-purpose AI (GPAI) rules on 2 August 2025, and most remaining requirements on 2 August 2026. This means the relevant dates for your company have already passed or are approaching fast, so it is crucial to know which phase applies to you and what needs to be done.

These deadlines are important because the AI Act’s obligations do not take effect all at once. For Lithuanian micro-enterprises, it is essential to distinguish between the already applicable AI literacy obligation, the GPAI rules, and the later high-risk system requirements. If you want to understand the regulation itself in more detail, start with the article EU AI Act explained simply.

When did the EU AI Act enter into force?

The EU AI Act is Regulation (EU) 2024/1689. It officially entered into force on 1 August 2024, but its obligations do not apply immediately. The regulation provides for a phased application to give companies and Member States time to prepare. As a result, instead of a single date, there are several phases, each introducing a new set of obligations.

It is important to understand the difference: the regulation "entered into force" in 2024, but specific obligations "start to apply" on different dates. For most micro-enterprises, the three most practically relevant moments are February 2025, August 2025, and August 2026.

What are the main phases of the EU AI Act?

Below is a table with all the key EU AI Act deadlines and what each date means in practice:

For most small Lithuanian companies that use AI tools in their daily work (e.g., ChatGPT for text, Copilot for code, or AI in accounting), the most relevant date in practice is 2 February 2025 due to the AI literacy requirement.

It is worth noting that not every phase affects all companies equally. The GPAI rules (2 August 2025) primarily apply to those who develop or provide AI models, not those who merely use them. High-risk requirements (2 December 2027 for Annex III and 2 August 2028 for relevant Annex I products) apply only in specific areas, such as recruitment or credit scoring. Therefore, before worrying about later dates, first clarify which group your company belongs to.

Why is 2 February 2025 the most important date for micro-enterprises?

Since 2 February 2025, Article 4 of the AI Act has applied, requiring providers and deployers to take measures to support the development of AI literacy among staff and relevant persons, considering their knowledge, experience, training, context, and affected individuals. This is the first obligation that applies to virtually every company using AI, regardless of size or sector. Unlike high-risk system requirements, AI literacy has no exceptions for small companies.

In practice, this means that your employees who use or supervise AI tools must understand how these tools work, their limitations, and risks. This obligation does not require a specific or sufficient individual level of literacy, nor does it mandate particular certificates, a fixed set of documents, a set number of training hours, external trainers, audits, or a dedicated AI officer. Companies are advised to document measures (e.g., training, guides, policies) as practical evidence, but this is not a legal minimum or a guarantee of compliance. For a detailed list of requirements, see the article AI Act Article 4 requirements.

If you are still unsure whether the regulation applies to you at all, read who the EU AI Act applies to - it explains which use cases include your company in the scope.

What needs to be prepared for each phase?

To avoid confusion, here is a concrete list of actions by date:

• By 2 February 2025 (already passed): Check that you are not using prohibited AI practices; prepare an AI usage policy, an employee AI guide, and compile a register of AI tools used; organise AI literacy training with knowledge checks. Note: certificates, a specific document bundle, fixed training hours, or external audits are not universally required.
• By 2 August 2025 (already passed): If you develop or provide general-purpose AI models, review GPAI provider obligations; most companies that only use AI do not need additional actions.
• By 2 December 2027 for Annex III or 2 August 2028 for relevant Annex I products: If your AI use falls into the high-risk category (e.g., recruitment, credit scoring), prepare for the corresponding requirements; this does not apply to most micro-enterprises, but it is worth checking.
• Ongoing: Update documents when tools or processes change. For more details, see updating AI documents.

If you want to see the entire collection of topics in one place, check the list of all articles.

Can the deadlines change?

The EU AI Act deadlines are fixed in the regulation itself, so they cannot be changed arbitrarily. However, for certain aspects (e.g., technical standards and guidelines), the European Commission may issue additional documents gradually. This means that the main dates remain stable, but detailed implementation requirements may be refined.

For micro-enterprises, this practically means one thing: do not wait for "final clarity", because the main obligation - AI literacy - is already in effect. It is better to have orderly documentation today and supplement it as needed than to start from scratch after receiving the first inquiry.

Which phase is most often overlooked?

The most frequently overlooked phase is precisely 2 February 2025 - AI literacy. Many small companies assume that the EU AI Act is only for large tech giants or high-risk systems, so they completely miss the literacy obligation. In reality, it applies to every company whose employees use any AI tool at work.

A second common mistake is thinking that a one-time effort is enough. AI literacy and documentation are not a "check and forget" task: when you change a tool or hire a new employee, documentation and training must be updated. This naturally links the deadlines to an ongoing process.

What is the difference between "entry into force" and "application start"?

These two concepts are often confused, so it is worth clarifying them. The AI Act’s entry into force (1 August 2024) means that the regulation became a binding EU legal act. However, the mere existence of the legal act does not yet impose obligations on companies - separate application start dates are provided for that.

A practical example: although the regulation "entered into force" in 2024, the AI literacy obligation only "started to apply" on 2 February 2025. Before that date, there were no literacy obligations. Similarly, high-risk system requirements exist in the regulation from 2024 but are only applied in practice from 2 December 2027 (Annex III) and 2 August 2028 (Annex I products). This phased approach gives companies a transition period, but it also means that missing a deadline is no longer "still early" - it is already late.

Are there exemptions for micro-enterprises regarding deadlines?

The EU AI Act provides certain simplifications for small and very small companies, particularly in terms of administrative burden and the scope of technical documentation. However, it is crucial to know that the AI literacy obligation (Article 4) has no exemptions - it applies equally regardless of company size. This makes sense because literacy is related to people, not the complexity of systems.

This means that a micro-enterprise cannot delay addressing literacy based on its size. Exemptions are more relevant for those who develop or deploy complex high-risk systems - in such cases, simplified technical documentation reduces the burden. For most service, trade, or IT micro-enterprises, it is sufficient to address the literacy aspect on time.

How to quickly ensure compliance with these deadlines?

A good way to start is to have four key documents: an AI usage policy, an AI tools register, a compliance record under Article 4, and an employee AI guide, plus AI literacy training with knowledge checks. These are practical ways to support the Article 4 measures applicable since 2 February 2025, with further duties assessed separately according to your use of AI. Our documents and quizzes are recommended practical records, not mandatory legal minimums or compliance guarantees.

All of this can be prepared manually or by using an automated solution. nebedirbam.lt automatically prepares this entire set of documents along with training and certificates for a fixed €149 + VAT (€299) price - based on compliance expert-reviewed templates, without hourly rates or waiting. If you first want only AI literacy training, you can start for free via free AI literacy training. The free path is for one signed-in participant; team training is included in the paid documentation package.

Summary: EU AI Act deadlines in brief

• 2024-08-01 - Regulation enters into force; countdown begins.
• 2025-02-02 - Prohibited AI practices and AI literacy (most important date for micro-enterprises).
• 2025-08-02 - General-purpose AI (GPAI) rules and governance structures.
• 2026-08-02 - General application, transparency and enforcement provisions; high-risk rules follow on 2 December 2027 (Annex III) or 2 August 2028 (relevant Annex I products).
• 2027-12-02 - High-risk AI listed in Annex III (final deadline).
• 2028-08-02 - High-risk AI embedded in Annex I products.

You can find the official regulation text on the EUR-Lex portal (Regulation (EU) 2024/1689), and the latest implementation information on the European Commission’s Digital Strategy page.

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The legal information in this article is based on official EU AI Act (AI Act) sources: AI Act Service Desk - Article 4 and European Commission’s AI regulatory framework.