The dates, and what each one changes.

Article 50 of the EU AI Act is already in force. What follows are the milestones that shift who is watching, and what they can do about what they find. This is a reading of published texts, not legal advice.

IN FORCE SINCE
2 August 2026
36 days ago
NEXT MILESTONE
2 December 2026
85 days · 09:52:25
FULL APPLICATION
2 February 2027
147 days · 09:52:25
  • 1 AUGUST 2024HISTORY

    The AI Act enters into force

    The regulation is law from this date, with obligations phasing in over the following three years. Article 50 covers transparency: telling people when they are looking at AI-generated or manipulated content.

  • 2 FEBRUARY 2025HISTORY

    Prohibited practices apply

    The first substantive deadline, unrelated to Article 50 but relevant as precedent: authorities demonstrated they were willing to act on the phase-in dates as written.

  • 2 AUGUST 2025HISTORY

    Governance and penalty structures take effect

    Member states designate authorities and the penalty framework becomes applicable. The maximum fines for transparency breaches are set at this point, though enforcement machinery is not yet in place.

  • 2 AUGUST 2026IN FORCE

    Article 50 transparency obligations apply

    From this date, providers and deployers must disclose AI-generated or manipulated content in a machine-readable form. This is the obligation Provena exists to satisfy.

    • Machine-readable marking on generated image, audio and video
    • Disclosure where content could mislead about real events or people
    • Exemptions for artistic and satirical work, documented rather than assumed
  • 2 DECEMBER 2026NEXT

    National enforcement structures operational

    Market surveillance authorities must be designated, resourced and able to act. In practice this is when requests for evidence start arriving with a legal basis behind them.

    • Authorities can request provenance records for specific published assets
    • Coverage per channel becomes the first question asked
    • Penalty application still discretionary in most member states
  • 2 FEBRUARY 2027FULL

    Full application of the obligations

    The remaining transitional allowances end. Systems placed on the market before the phase-in dates lose their grace period, and the transparency requirements apply uniformly.

    • No further transitional relief for existing systems
    • Retroactive evidence is not possible; the record is what it is
  • 2027 ONWARDSOUTLOOK

    Standards harmonisation and codes of practice

    Harmonised standards for provenance marking are expected to consolidate around C2PA. Codes of practice will define what a reasonable technical effort looks like — which is where a coverage figure with named exceptions becomes the defensible answer.

This page reflects published texts and guidance as of September 2026. National implementations differ, and dates have moved before. Verify against your own counsel before acting.

The structures arrive in December. The evidence has to exist before then.

Coverage cannot be backfilled. An asset published unmarked in October stays unmarked in the record.

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