What the EU AI Act requires now.
GPAI is in force. Article 50 is live, with marking for generative systems already on the market due 2 December 2026. The AI Omnibus is law: high-risk obligations start 2 December 2027.
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 from 2 August 2026. Generative AI systems placed on the market before that date must meet the Article 50(2) marking duty by 2 December 2026. | GW Slate™ marks AI-generated audio, image and video with C2PA Content Credentials and AI-generated text with a signed AI mark, and Iris Meridian™ tells each person at first contact that she is AI. | Actuality Receipt for every action — provenance, authority, logic, and outcome. |
| Annex III high-risk obligations, including Article 14 human oversight, apply from 2 December 2027 under the AI Omnibus, in force since 27 July 2026. | 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 high-risk obligations apply from 2 August 2028 under the AI Omnibus, in force since 27 July 2026. 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 are 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. |
Sources
Dated records for the deadlines on this page.
Last reviewed: 2026-10-24
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; generative AI systems placed on the market before that date must meet the Article 50(2) marking duty by 2 December 2026. The AI Omnibus, published in the Official Journal on 24 July 2026 and in force since 27 July 2026, sets high-risk obligations at 2 December 2027 for Annex III systems and 2 August 2028 for Annex I systems. Maximum penalties are EUR 35 million or 7% of global annual turnover. Receipt Rail™ keeps the record behind each Article 50 duty: a tamper-evident Actuality Receipt™ showing what was generated, how it was disclosed or marked, under which policy, and who approved it.
02When do Annex III high-risk obligations apply?
An Annex III high-risk system is an AI system listed in Annex III of the EU AI Act. Under the AI Omnibus, in force since 27 July 2026, high-risk obligations for Annex III systems, including Article 14 human oversight, apply from 2 December 2027.
03When do Annex I system obligations apply?
The AI Omnibus, in force since 27 July 2026, sets high-risk obligations for Annex I systems at 2 August 2028 and for Annex III systems at 2 December 2027. Annex I and Annex III stay separate.
04What evidence does Receipt Rail™ produce for Article 50?
Receipt Rail™ keeps the record behind each Article 50 duty: a tamper-evident Actuality Receipt™ showing what was generated, how it was disclosed or marked, under which policy, and who approved it.
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The certifiable AIMS and the audit record.
Operational controls inside the workflow.
The Actuality Receipt an auditor samples.