Twelve questions. Five minutes. Where you actually stand against the obligations that apply to you, sent to your inbox with your answers, question by question.
The deadline everyone prepared for was moved. The one almost nobody is talking about is in .
Most organisations spent a year preparing for . Then the Digital Omnibus deferred the high-risk regime to and , and the parts that did come into force on schedule went largely unnoticed: the transparency duties in Article 50, which are live and enforceable now.
This is not a compliance assessment. It is twelve questions that tell you which obligations are actually yours, which of them have already started, and what to do first.
The obligations that apply to you depend on two things: whether you are in scope at all, and whether you are the provider or the deployer of each AI system. The first two questions settle both, and the rest of the check changes accordingly.
Part of the RAISE Method. Read how a RAISE assessment runs.
| Status | Date | What |
|---|---|---|
| In force | 2 February 2025 | Prohibited practices (Article 5) |
| 2 February 2025 | AI literacy (Article 4) in force, softened by the omnibus to supporting the development of AI literacy among staff rather than guaranteeing a level | |
| 2 August 2025 | General-purpose AI model obligations (Articles 51 to 56), governance, national penalties | |
| 2 August 2026 | Article 50 transparency: chatbot disclosure, marking of generated content, emotion recognition notices, deepfake disclosure | |
| 2 August 2026 | Commission fines for general-purpose AI model providers (Article 101) | |
| Next deadline | 2 December 2026 | Machine-readable marking of outputs for generative systems already on the market before 2 August 2026 (Article 111(4)) |
| 2 December 2026 | Two new Article 5 prohibitions: non-consensual intimate deepfakes, and child sexual abuse material | |
| Ahead | 2 August 2027 | General-purpose AI models placed on the market before 2 August 2025 |
| 2 August 2027 | National AI regulatory sandbox | |
| 2 December 2027 | High-risk, Annex III stand-alone systems (employment, credit, education, biometrics) ahead, deferred from 2 August 2026 | |
| 28 January 2028 | Notified bodies to apply for designation | |
| 2 August 2028 | High-risk, Annex I systems embedded in regulated products (medical devices, machinery, lifts) ahead, deferred from 2 August 2027 | |
| 2 August 2030 | High-risk systems used by public authorities, including those already in service |
Dates last reviewed on 3 November 2026.
A reference model of 60 capabilities an organisation must hold to run AI safely, each traced to a recognised standard (ISO/IEC 42001, the international AI management standard, and NIST's AI Risk Management Framework among them); a nine-rung ladder from foundations to autonomous agents, with a gate before each step; and generated board and technical plans that your board and your IT team can work from.
Built on twenty years of Microsoft enterprise architecture and information governance work. The current version was applied at a large UK charity through 2026. Delivered by RAISE.AI (Gembitz Ltd, est. 2017). Book an intro call or write to ossama@raiseai.co.