Regulation · September 2026 · 4 min
Regulation is an occasion, not the main argument
The AI Act's high-risk rules have been postponed to December 2027, not cancelled. And several requirements already apply today.
Anders Butzbach Christensen
Plan & Proof
AI literacy is enforced from August 2026. The Data Act largely applies already. That is a concrete occasion to get governance in order, but it is rarely the best reason to write a strategy.
The timeline
AI Act art. 4: AI literacy requirement applies
Applies
Data Act: most rules apply
Applies
Literacy enforced, and transparency requirements (art. 50) apply
Applies
Data Act: design requirements for new connected products
Applies
Watermarking for systems on the market before August 2026
Coming
Data Act: contract rules for older B2B agreements
Coming
High risk, Annex III: e.g. recruitment, credit and education
Coming
High risk, Annex I: AI in regulated products
Coming
What it means for you
Data, governance and literacy take 12-24 months to build and are the same regardless of technology. Waiting for the technology to mature does not move the requirements.
Not legal advice. Always check the current legal text, or have a lawyer review it.
Sources: Digital Omnibus on AI (Regulation 2026/1744); Gibson Dunn, 27 May 2026; Clifford Chance, 19 Sep 2025.
The service behind this article: AI literacy programme →