The AI Act's forgotten clause: models placed on the market before August 2025 have until August 2027 to comply
Enforcement powers activate today, but the Act carries a two-tier calendar. General-purpose models placed on the EU market before 2 August 2025 must be brought into compliance by 2 August 2027 — a two-year runway that models shipped after that date never received. The split decides which providers face immediate exposure and which have another year to prepare.
The grandfather clause is the quiet counterpart to today's headline. A model already on the market when the obligations took effect could not retroactively satisfy training-time duties, so the Act gives that cohort until August 2027 to conform. Everything shipped since August 2025 gets no such grace — it was expected to comply from the day it launched.
The effect is a compliance map with sharp edges. A provider whose flagship predates August 2025 has breathing room on that specific model; the same provider's newer releases do not. And because the frontier ships a new model roughly every week now, the protected legacy cohort shrinks by the month while the immediately-liable cohort grows.
The trap is reading 'until 2027' as a general reprieve. It applies only to the pre-August-2025 vintage, and only to bringing those specific models into line. The transparency duties and the enforcement powers that landed today apply to the current generation now, which is why a firm that leans on the 2027 date for its whole portfolio is misreading the calendar.
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