EU lawmakers are reportedly considering a delay in the enforcement of certain provisions of the EU Artificial Intelligence Act (AI Act). While the AI Act formally entered into force on 1 August 2024, its obligations apply on a rolling basis. Requirements related to AI literacy and the prohibition of specific AI practices have been applicable since 2 February 2025. Additional obligations are scheduled to come into effect on 2 August 2025 (general-purpose AI (GPAI) model obligations), 2 August 2026 (transparency obligations and obligations on Annex III high-risk AI systems), and 2 August 2027 (obligations on Annex I high-risk AI systems). The timeline and certainty of regulatory enforcement of these future obligations now appears uncertain.
The AI Act is not the only AI measure facing a delay. The publication of a code of practice for GPAI models—originally expected by 2 May 2025 under Article 56(9) of the AI Act—has been delayed, following concerns about drafts of the code expressed by a range of stakeholders. In addition, the technical standards intended to support regulated actors in demonstrating compliance with the AI Act have yet to be published. Against this backdrop, Poland, in its role holding the rotating Presidency of the Council of the EU, has reportedly proposed delaying the dates of application of the AI Act.
No formal delay has been announced at the time of writing and the method of executing any such delay is not yet known. That said, based on recent precedent, the Commission could adopt a simple directive or regulation that effectively stops the clock. In 2024, for example, the EU adopted a regulation amending the Deforestation Regulation (Regulation (EU) 2023/1115) to delay its application by one year. And in 2025, the EU adopted a directive delaying certain aspects of the Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464) and the Corporate Sustainability Due Diligence Directive (Directive (EU) 2024/1760). The latter was proposed by the Commission and adopted and published in under seven weeks—one of the fastest EU legislative procedures ever. If the EU wants to delay GPAI model obligations prospectively, it will need to act fast. 2 August 2025—the date that the obligations on GPAI models begin to apply— is fast approaching. The last European Parliament plenary before the summer break—at which the Parliament would need to adopt its position—is the week of 7 July 2025. The Council and Parliament would need to complete negotiations before 10 July for the Parliament to approve the deal in Plenary before the summer break. Although not impossible, it would require clear political will to push this through.
This blog was drafted with the assistance of Dumitha Gunawardene, a trainee in the London office.