Status of the AI Act today.
Regulation (EU) 2024/1689 (the AI Act) entered into force on 1 August 2024 and applies in stages. Prohibited AI practices (Art. 5) and AI literacy obligations (Art. 4) have applied since 2 February 2025. Rules for general-purpose AI models, governance and penalties apply from 2 August 2025. Stand-alone high-risk AI systems (Annex III) are scheduled for 2 August 2026, and high-risk AI embedded in regulated products (Annex I) for 2 August 2027.
What the Commission has actually proposed.
The Digital Package on Simplification (COM(2025) 868, 19 November 2025) is a Commission proposal, not an adopted text and not a trilogue agreement. Among other measures, the Commission acknowledges that delayed availability of harmonised standards, common specifications and guidance jeopardises effective application of the high-risk regime on 2 August 2026, and proposes a mechanism that links the start of those obligations to the availability of such compliance-supporting measures — potentially deferring high-risk obligations by up to 16 months.
What stays the same.
Penalties under Article 99 are unchanged: up to EUR 35 million or 7% of worldwide annual turnover for prohibited practices, and up to EUR 15 million or 3% for other infringements — whichever is higher. The systemic-risk threshold for general-purpose AI models in Article 51 (training compute above 10^25 FLOPs) also remains in place.
What it means for Regweaver customers.
Simplification is not deregulation. The AI Act still applies — the timeline may bend to reality, but the obligations do not disappear. RegCheck tracks proposals like the Digital Package alongside the in-force text, so customers see both the current legal baseline and the realistic path forward.
Key takeaway
Treat the Digital Package as a Commission proposal, not a done deal. Plan against the in-force AI Act timeline, and use the proposed delay mechanism as upside — not as a reason to wait.
This article is for informational purposes only and does not constitute legal advice.
Related reading
- Regulatory update
The AI Act now has fixed dates — what Regulation (EU) 2026/1744 actually changed
The trigger-plus-six-months construct is gone. The enacted text sets unconditional calendar dates for the high-risk regime.
Read article - NIS2
NIS2 Value Chain Obligations: What Suppliers Actually Need to Provide
Essential and important entities are pushing security requirements downstream. Here is what evidence suppliers should be ready to provide.
Read article - Regulatory update
Regulation in motion 2026 — why a correct regulatory assessment starts ageing immediately
Five regulatory changes in seven months. None of them are matters of opinion: thresholds, application dates and national implementation actually moved.
Read article