Unit 5 of 5

3.5 — Enforcement and Timeline

The EU AI Act uses a phased enforcement timeline, with different provisions taking effect at different dates. This approach gives organizations time to prepare for compliance while ensuring the most critical prohibitions take effect first. Understanding this timeline is essential for exam preparation.

EU AI Act Enforcement Timeline
Aug 1, 2024
Entry into Force
The EU AI Act officially enters into force. The countdown begins for all phased deadlines.
Feb 2, 2025
Prohibited Practices + AI Literacy
Prohibited AI practices (Article 5) become enforceable. AI literacy obligations (Article 4) also take effect. Organizations must have discontinued all banned practices and begun AI literacy training.
Aug 2, 2025
GPAI Rules
Rules for General-Purpose AI models take effect. GPAI providers must comply with documentation, copyright, and training data summary obligations. Systemic risk models must meet additional requirements.
Aug 2, 2026
High-Risk Annex III Systems
Full requirements for high-risk AI systems listed in Annex III (standalone AI in biometrics, employment, education, law enforcement, etc.) become enforceable.
Aug 2, 2027
High-Risk Annex I Systems
Requirements for high-risk AI systems that are safety components of products covered by EU harmonization legislation (Annex I) become enforceable.

Penalties and Enforcement Structure

Penalty Structure
Violation TypeMaximum Fine (EUR)Alternative (% Global Turnover)SME/Startup Cap
Prohibited AI PracticesUp to 35 million EUR7% of global annual turnoverProportionate, lower caps apply
High-Risk System ViolationsUp to 15 million EUR3% of global annual turnoverProportionate, lower caps apply
GPAI Model ViolationsUp to 15 million EUR3% of global annual turnoverProportionate, lower caps apply
Incorrect/Misleading Information to AuthoritiesUp to 7.5 million EUR1% of global annual turnoverProportionate, lower caps apply

National Competent Authorities and Market Surveillance Authorities enforce the Act in each EU member state. Each member state must designate at least one notifying authority and one market surveillance authority. The European AI Office (within the European Commission) handles enforcement for GPAI models at the EU level and coordinates across member states.

AI Literacy (Article 4) is a cross-cutting obligation that took effect alongside the prohibitions in February 2025. It requires all providers and deployers to ensure sufficient AI literacy among their staff and other persons dealing with the operation and use of AI systems on their behalf. The level of literacy must account for technical knowledge, experience, education and training, the context of use, and the persons or groups affected.

AI Literacy — Often Overlooked

AI Literacy (Article 4) is frequently tested because candidates overlook it. Key facts: (1) It applies to ALL providers and deployers, not just high-risk. (2) It took effect in February 2025, making it one of the EARLIEST obligations. (3) It is NOT limited to technical staff — it covers anyone dealing with AI systems. (4) The required literacy level is context-dependent, not a fixed standard.

The penalty amounts are the HIGHER of the fixed EUR amount or the percentage of global annual turnover, whichever is greater. For companies that are part of a larger group, global annual turnover refers to the entire group's worldwide turnover. SMEs and startups receive proportionate caps to avoid disproportionate penalties that could threaten their viability.

Key Points
Fines up to 35M EUR or 7% global turnover (whichever is higher)
Phased timeline: Feb 2025 → Aug 2025 → Aug 2026 → Aug 2027
AI literacy obligation effective February 2025 — applies to ALL
National authorities + AI Office enforce jointly
SMEs receive proportionate penalty caps
Each member state designates competent authorities
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