The EU's transparency duties are the part that actually switched on
Since 2 August a chatbot in the EU has had to say it is a chatbot and synthetic media has had to carry a label. Coverage keeps folding the high-risk regime into the same date. It is not in force, and the gap between the two is where compliance budgets are being misspent.
Two things became enforceable in the European Union on 2 August 2026: the obligations on general-purpose AI models, and the transparency duties. A system that converses with a person must disclose that it is a system. Content that has been generated or materially altered by a model must be labelled as such. Those are the rules with teeth this month.
That is not what a large share of the coverage says. Guides published in the last three weeks state that the majority of remaining provisions — including the core duties for high-risk systems — apply from the same date. They do not. Stand-alone high-risk systems under Annex III were moved to 2 December 2027, and high-risk components embedded in regulated products under Annex I to 2 August 2028. The delay was granted precisely because the standards work was not finished.
The distinction is not pedantry, it is money. A company reading the wrong date builds a conformity-assessment programme eighteen months early and, worse, treats the transparency obligation as one line item inside it rather than as the thing that is actually enforceable now. The penalty exposure attached to the transparency articles is up to €15 million or 3% of worldwide turnover. The 7% tier belongs to the prohibited-practices regime, which is a different article and a different list.
The honest summary for anyone shipping into the EU this quarter: label your synthetic media, disclose your bots, document your general-purpose model, and do not let a vendor sell you a high-risk conformity package on a deadline that does not exist yet. The next date that genuinely binds is in December, and it is narrower than the one being marketed.
European Commission — Commission starts enforcing AI Act rules and new transparency requirements on 2 August → · European Commission — AI Act — regulatory framework → · Help Net Security — EU begins enforcing AI Act, putting AI models under the microscope →