What the EU AI Act requires now.
GPAI is in force. Article 50 is live. High-risk dates from the Digital Omnibus stay agreed, pending Official Journal publication.
What does the EU AI Act require of us now
Requirement, controller, artifact.
Requirement names the instrument. What GW Slate™ does is the existing controller capability. The artifact is what an auditor samples. Counsel decides what an obligation requires of a given deployment.
| Requirement | What GW Slate™ does | The artifact an auditor samples |
|---|---|---|
| GPAI model obligations — in force since 2 August 2025. | GW Slate™ is the modular controller and human command surface. It routes each task to the model that fits, holds authority and policy on the controller, and runs multi-agent workflows to completion. | The routing record on the Actuality Receipt: which model ran, under which policy, on which workflow. |
| Article 50 transparency and synthetic-content duties — apply 2 August 2026. Live now. Unchanged by the Digital Omnibus. | Receipts vs watermarks — a watermark tells you AI was used; a receipt records who acted, on what data, under what policy, and what resulted. | Actuality Receipt for every action — provenance, authority, logic, and outcome. |
| Annex III high-risk systems — Digital Omnibus moves obligations to 2 December 2027. Agreed, not yet adopted; the date binds only on Official Journal publication. | An Actuality Receipt is a tamper-evident cryptographic record emitted by Receipt Rail™ proving an AI action's provenance, authority, logic, and outcome — auditable proof a regulator or counterparty can check. | The Actuality Receipt an auditor samples for who acted, under which policy, with what authority, and what resulted. |
| Annex I systems — Digital Omnibus moves obligations to 2 August 2028. Agreed, not yet adopted; the date binds only on Official Journal publication. Annex I and Annex III stay separate. | Actuality Receipts for every consequential step — provenance, authority, logic, outcome. | Provenance, authority, logic, and outcome on every consequential step — the four dimensions of the Actuality Receipt. |
| Maximum penalties — EUR 35 million or 7% of global annual turnover. | Receipt Rail™ is the proof layer. Every governed action emits an Actuality Receipt — who, what, policy, and outcome. | The sealed packet: identity, data class, policy version, human action, and outcome on the receipt. |
Last reviewed: 2026-09-08
Questions
01What does the EU AI Act require of us now?
GPAI model obligations have been in force since 2 August 2025. Article 50 transparency and synthetic-content duties apply from 2 August 2026 — live now, unchanged by the Digital Omnibus. Receipt Rail™ emits an Actuality Receipt for every governed action so the disclosure record is sampleable.
02When do Annex III high-risk obligations apply?
The Digital Omnibus provisional political agreement of 6 May 2026, confirmed by Member States on 13 May 2026, moves high-risk obligations for Annex III systems to 2 December 2027 — agreed, not yet adopted; the date binds only on Official Journal publication.
03When do Annex I system obligations apply?
The same Digital Omnibus agreement moves high-risk obligations for Annex I systems to 2 August 2028 — agreed, not yet adopted; the date binds only on Official Journal publication. Annex I and Annex III stay separate.
04What evidence does Receipt Rail™ produce for Article 50?
Article 50 transparency and synthetic-content duties apply from 2 August 2026 — live now, unchanged by the Digital Omnibus. An Actuality Receipt is a tamper-evident cryptographic record emitted by Receipt Rail™ proving an AI action's provenance, authority, logic, and outcome — auditable proof a regulator or counterparty can check.
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Govern, Map, Measure, Manage on agentic systems.
The certifiable AIMS and the audit record.
Operational controls inside the workflow.
The Actuality Receipt an auditor samples.