Transition rules: what existing AI systems need to do by when
Article 111 sets transition provisions for AI systems already on the market. Understand which deadlines apply to your existing deployments and when grandfathering ends.
The general rule: August 2, 2026
High-risk AI systems placed on the market or put into service before August 2, 2026 need not comply with the new high-risk requirements unless they undergo significant modifications after that date. A significant modification means a change that affects the system's compliance with the requirements or modifies its intended purpose.
This grandfathering provision gives organizations time to bring existing systems into compliance, but tracking whether a modification qualifies as 'significant' requires disciplined change management.
Special timelines
GPAI models already on the market before August 1, 2025 have until August 2, 2027 to comply with Articles 53-56. AI systems used by public authorities receive extended timelines up to August 2, 2030. Large-scale IT systems listed in Annex X (SIS II, VIS, Eurodac, etc.) have until December 31, 2030.
Article 6(1) products — AI safety components of harmonised products requiring third-party conformity assessment — must comply by August 2, 2027.
Practical approach
Inventory all existing AI systems and map each to its applicable transition deadline. Implement change monitoring to flag significant modifications that would trigger immediate compliance requirements.
ActLoom's transition-rule evaluator automatically determines the applicable deadline for each registered system based on its classification, deployment date, and use context, so your team always knows which systems need action and by when.