AI Act Deadline Extensions Do Not Remove the Classification Work
A National Law Review analysis of the Commission's draft high-risk guidelines notes that Article 6(2) and Annex III obligations now apply from 2 December 2027, while Article 6(1) and Annex I obligations apply from 2 August 2028.
BY TRANSATLANTIC DESK · JUNE 10, 2026 · 1 MIN READ
A National Law Review analysis of the Commission's draft high-risk guidelines notes that Article 6(2) and Annex III obligations now apply from 2 December 2027, while Article 6(1) and Annex I obligations apply from 2 August 2028. The draft is not yet legally binding, but it gives providers and deployers additional time to assess system classification and prepare documentation. Deadline movement should not be read as a pause in compliance. Law firms and in-house teams still need AI inventories, purpose statements, deployment maps, vendor contracts and escalation processes now, especially where tools may be used in employment, public authority, litigation, regulatory or access-to-rights contexts.