AI governance
EU AI Act compliance for B2B teams
The risk levels, the roles, the dates as amended in July 2026, and the first steps for a company that builds or uses AI.
Key takeaways
- The Act sorts AI into prohibited, high-risk, transparency and minimal risk.
- Your duties depend on your role, provider or deployer, for each system.
- Prohibitions and AI literacy have applied since 2 February 2025.
- The AI Omnibus moved Annex III high-risk duties to 2 December 2027.
- Start with an inventory of every AI system and its intended purpose.
The EU AI Act sorts AI systems by risk. Prohibited practices and AI literacy rules have applied since February 2025, rules for general-purpose models since August 2025, and most other rules since August 2026. The AI Omnibus moved high-risk obligations to December 2027 for Annex III uses and August 2028 for regulated products.
What is the EU AI Act?
The AI Act, Regulation (EU) 2024/1689, is the EU's law on artificial intelligence. It entered into force on 1 August 2024 and applies in stages.[1][2] It regulates AI systems by the risk their use creates, not by the technology behind them, and it reaches companies outside the EU when their AI systems are placed on the EU market or used there.
For a B2B company the practical questions are three: which of your AI systems fall into which risk level, what role you play for each one, and which dates apply. This guide covers all three. It is not legal advice: confirm your obligations with your own legal adviser.
Which risk levels does the Act use?
The Commission describes four:[1]
| Risk level | What it means | Examples from the Commission |
|---|---|---|
| Unacceptable | Banned outright | Social scoring; inferring emotions of staff at work |
| High | Strict duties before and after launch | Exam scoring; CV-sorting tools for recruitment |
| Transparency | People must know AI is involved | Chatbots; deepfakes and other generated content |
| Minimal | No new rules | Spam filters; AI in video games |
Most AI that B2B teams use, such as drafting, summarizing or internal search, sits in the minimal or transparency levels. The risk rises with the purpose: the same model that drafts sales emails becomes high-risk if you use it to rank job applicants.
What changed with the AI Omnibus?
The dates for high-risk systems. The Commission proposed the Digital Omnibus on AI on 19 November 2025.[1] It was adopted as Regulation (EU) 2026/1744 on 8 July 2026, published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026.[3]
| Rules | Apply from |
|---|---|
| Prohibited practices and AI literacy | 2 February 2025 |
| Governance and general-purpose AI model obligations | 2 August 2025 |
| Most other rules, including transparency | 2 August 2026 |
| High-risk systems in Annex III use cases | 2 December 2027 |
| High-risk AI in regulated products, Annex I | 2 August 2028 |
The first three rows come from the original Act as the Commission summarizes it; the last two are the amended dates.[1][3] The Omnibus also gives providers of generative systems placed on the market before 2 August 2026 until 2 December 2026 to meet the rule on marking generated content, and it rewrites AI literacy as a duty for providers and deployers to "take measures to support the development of AI literacy of their staff".[3]
Which of your AI uses does the Act touch?
A free growth diagnostic reviews two or three of your most time-heavy workflows, your data readiness, quick wins with current tools, and the data and policy risks, and ranks your top 3 use cases by value and effort. Your top 3 findings and a 30-day fix plan in writing within 2 business days.
Are you a provider or a deployer?
It depends on the system, so answer it for each one. A provider develops an AI system, or has one developed, and places it on the market or puts it into service under its own name. A deployer uses an AI system under its own authority, other than for personal, non-professional use.[2] A SaaS company that ships an AI feature is a provider of that feature; the same company using a vendor's recruiting tool is a deployer of it.
The line can move. A deployer or other third party is treated as the provider of a high-risk system if it puts its name or trademark on one, makes a substantial modification that keeps it high-risk, or changes a system's intended purpose so that it becomes high-risk.[2]
What must deployers of high-risk AI do?
Article 26 sets the main duties.[2] Deployers must:
- take appropriate technical and organizational measures to use the system according to its instructions for use;
- assign human oversight to people with the necessary competence, training and authority;
- keep the logs the system generates, where they control them, for at least six months unless other law requires otherwise;
- as employers, inform workers' representatives and affected workers before a high-risk system is used at the workplace.
Providers carry the heavier load: risk management, data governance, technical documentation, logging by design, conformity assessment and registration. For Annex III systems those duties now start on 2 December 2027.[3]
What about chatbots and AI content?
Transparency rules apply to everyone in scope, whatever the risk level. Providers must design systems that interact directly with people so those people are told they are dealing with AI, unless it is obvious from the context, and must mark synthetic output "in a machine-readable format".[2] The Commission adds that deepfakes and certain public-interest text must be clearly and visibly labeled.[1] It has published guidelines on these obligations.[1]
What applies to general-purpose AI models?
Obligations for providers of general-purpose AI models have applied since 2 August 2025.[1] Most B2B companies use these models through an API rather than provide them, so the duties fall on the model vendor. The Commission published a voluntary General-Purpose AI Code of Practice on 10 July 2025, with chapters on transparency, copyright, and safety and security, that providers can use to show compliance.[4]
If you fine-tune or substantially change a model and offer it under your name, check with your adviser whether you have become a provider. Our guide to AI governance for LLM training covers the data controls that matter either way.
Where should a B2B team start?
-
Inventory every AI system you build or use, with its owner, vendor and intended purpose.
-
Classify each one by risk level and record your role, provider or deployer.
-
Check transparency on every customer-facing chatbot and every generated image, audio or video.
-
Plan high-risk work against the amended dates, and ask vendors for their documentation and instructions for use.
-
Run AI literacy training for the staff who use or oversee these systems.
Pair the inventory with technical controls: prompt injection gateways for systems that read outside content, and hallucination verification for answers people act on. Our AI governance service covers the inventory and policy steps as part of our AI consulting work.
Sources
Written under our Editorial and AI Policy. Sources checked 19 Oct 2026. Reviewed by DGo Digital on 19 Oct 2026.
FAQ
Questions about the EU AI Act
Yes. The Digital Omnibus on AI, Regulation (EU) 2026/1744, entered into force on 27 July 2026. High-risk obligations now apply from 2 December 2027 for Annex III use cases and from 2 August 2028 for AI built into products regulated under the EU product laws listed in Annex I of the Act. Other parts of the Act already apply.